Carolyn A. Glenn - Page 4

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               Petitioner and Mr. Glenn were married on July 8, 1989.  For            
          taxable year 2001, petitioner and Mr. Glenn filed a timely joint            
          Federal income tax return.  During the year in issue, petitioner            
          and Mr. Glenn were married and resided in the same household;               
          however, they occupied separate rooms in the household.  Their              
          2001 Federal income tax return was signed and dated by both of              
          them on April 10, 2002.  Petitioner and Mr. Glenn executed the              
          2001 return voluntarily.  Petitioner had filed for divorce from             
          Mr. Glenn in October of 2001.  They were divorced on November 13,           
          2002.  Their judgment for dissolution of marriage provided:                 
               That each party shall be responsible for the payment of all            
               credit card bills and all other debts in his or her name               
               alone.  Each shall hold the other harmless and indemnify the           
               other from the respective indebtedness.                                
          However, the judgment for dissolution of marriage did not address           
          payment of joint liabilities.                                               
               On their jointly filed 2001 tax return, petitioner and Mr.             
          Glenn reported wage income of $157,301, interest income of $350,            
          and total pension and annuity income of $165,838.3  Petitioner              
          and Mr. Glenn reported adjusted gross income of $323,489 and                
          claimed deductions of $31,811 on Schedule A, Itemized Deductions.           
          Their 2001 income tax return reported a total tax of $86,293 and            
          a net amount owed of $21,438 after reducing their total tax by              
          the amount of income tax withheld.                                          


          3This amount is rounded to the nearest dollar.                              





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