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March 26, 1993, respectively. Petitioner and respondent entered
into timely agreements extending the period for assessment for
each tax year in controversy.
Petitioner married Jo Ann Corrigan (Mrs. Corrigan) during
1965, and they had four children. Petitioner holds a master’s
degree in finance and in business administration and began
working as a stockbroker in southern California during 1970.
Beginning in 1976, petitioner began working as a stockbroker in
San Francisco, California. Although petitioner and Mrs. Corrigan
legally separated during 1973, they moved to Walnut Creek,
California, and lived together in a home with their children.
Petitioner and Mrs. Corrigan jointly purchased the home in Walnut
Creek for $89,000. They remodeled the Walnut Creek home and
added a barn and horse stables to the property at a cost of
approximately $70,000. After the improvements, Mrs. Corrigan
began boarding, breeding, and showing horses.
At the time of their 1973 separation, petitioner and Mrs.
Corrigan entered into a property settlement agreement providing
for child support, custody, and alimony. Mrs. Corrigan was given
physical and legal custody of the four children under the
agreement. On what purported to be joint returns for 1987
through 1991, petitioner claimed dependency exemptions for his
four children and a personal exemption for Mrs. Corrigan.
Respondent conceded that petitioner is entitled to file the
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