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1997 10-15-98 11-25-98 109,797 85,362 19,712
1998 8-15-99 2-11-00 107,293 80,099 17,684
1999 10-15-00 8-29-00 137,411 106,912 25,632
1The parties have been unable to locate a copy of the 1991 return. Records
that respondent maintained in the ordinary course of business reflect that
petitioner and Levy reported having an adjusted gross income of $4,539, a
self-employment tax liability of $10,247, and tax due of $10,247.
2The parties have been unable to locate a copy of the 1996 return. Records
that respondent maintained in the ordinary course of business reflect that
petitioner and Levy reported having an adjusted gross income of $124,753, a
taxable income of $105,291, a self-employment tax liability of $560, and
tax due of $25,080.
None of the above balance due amounts were paid when the return
for that year was filed.
No discussions took place between petitioner and Levy about
the preparation or filing of the 1991, 1992, 1993, 1994, 1995,
1996, 1997, 1998, and 1999 returns. Nor did petitioner and Levy
discuss the payment of the unpaid tax liability.
As of the date of the trial in this case, with the exception
of 1991 tax liability, the Levys’ tax liabilities remained
unpaid. During 2001 petitioner sold two residential real
properties and was entitled to real estate commissions of
$24,300.13. On June 22, 2001, respondent levied on petitioner’s
$24,300.13 of real estate commissions and applied the proceeds to
fully satisfy the 1991 joint tax liability.
D. Petitioner and Levy’s Divorce and Levy’s Bankruptcy Filing
Petitioner and Levy were divorced on June 13, 2002.
Petitioner received the Key Biscayne condominium as part of the
dissolution of the marriage. Levy also was required to pay
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