Linda K. Haltom - Page 2

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          failed to report the embezzled income, and Linda now seeks                  
          innocent spouse relief under section 6015(b) and (f) from the               
          resulting deficiencies. 1                                                   
                                  FINDINGS OF FACT                                    
               Linda and Jerry Haltom wed in 1974, and settled in Smyer, a            
          small town in West Texas where they reared their two children.              
          Jerry is a college graduate who took courses in accounting and              
          earned a degree in business administration.  He worked for many             
          years as a food broker at Oliver Taylor Company West, Inc.  While           
          Jerry advanced at the Taylor Company, Linda cared for their                 
          children and ran the household.  She had no formal education                
          beyond high school, and rarely worked outside the home until                
               Food brokerage is part salesmanship and part marketing, and            
          Jerry’s job was to work with food manufacturers such as Del                 
          Monte, Heinz, and Capri Sun to get their products into                      
          supermarkets and wholesalers throughout West Texas.  He drew a              
          salary, but would often more than double that income through                
          commissions, bonuses, and awards.                                           
               By the late 1980s, a culture of fraud had taken hold in                
          several West Texas food brokerage companies.  Over several years,           
          18 people from three different firms were convicted for cheating            

               1 All references to sections are to sections of the Internal           
          Revenue Code, and the one reference to a Rule is to the Tax Court           
          Rule of Practice and Procedure 155.                                         

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Last modified: May 25, 2011