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joint and several Federal income tax liability. We hold that she
is not.
FINDINGS OF FACT
I. Overview
Some facts are stipulated. We incorporate herein by this
reference the parties’ stipulations of fact and the exhibits
submitted therewith. We find the stipulated facts accordingly.
Petitioners resided in Eugene, Oregon, when their petition
was filed in this Court. They timely filed a 1986 joint Federal
income tax return (1986 return). Sam F. Ford (Mr. Ford) has one
child, Marc J. Ford (Marc Ford), who lives in Chicago, Illinois.
Ms. Ford was born in Indonesia but has lived in the United States
since 1960. She has no children.
In 1983, Ms. Ford worked as a secretary and bookkeeper at
International Tillex in New York, New York, a business owned by
her cousin, Robert Doorn (Mr. Doorn). While there, she exercised
a stock option for $32,500 of International Tillex shares, which
she sold at a profit. She also had a brokerage account with
Yorkton Securities, Inc. She met Mr. Ford during 1983, and they
married on February 7, 1986. During the early months of their
marriage, petitioners rented a house in Beverly Hills,
California. In 1986, Mr. Ford was self-employed.
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