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Petitioners resided in Kentucky when their petitions were filed
with the Court. They were married on December 31, 1991, and they
have been husband and wife ever since. At all relevant times,
petitioner has been a licensed practicing attorney in Kentucky.
Petitioner filed his 1989 and 1990 Federal income tax
returns on November 18, 1991, using the filing status of
“Single”. Those returns reported that petitioner had one
dependent (a daughter) for 1989 and two dependents (a son and
daughter) for 1990, and total income of $35,737 for 1989 and
$13,864.30 for 1990. Petitioner filed his 1991 Federal income
tax return on December 7, 1992, using the filing status of
“Single”. That return reported that petitioner had two
dependents (a son and a daughter) and total income of $15,532.
Petitioners filed a joint 1992 Federal income tax return on April
15, 1993. That return reported that petitioners had two
dependents (petitioner’s son and daughter) and total income of
$16,633. Petitioners filed a joint 1993 Federal income tax
return on November 4, 1994. That return reported that
petitioners had two dependents (petitioner’s son and daughter)
and total income of $36,696. Almost all of the total income
reported on these five returns was attributable to petitioner’s
practice as a self-employed attorney. The 1990 and 1991 returns
reported that petitioner owed tax of $2,125.17 and $3,045.47,
respectively. The 1992 and 1993 returns reported that
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