Sam F. Ford and Ingrid D. Ford - Page 3

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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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