Yvonne C. Lopez - Page 4

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          Mr. Cowdery was not making payments to the IRS because of the               
          levy.  Although petitioner was aware of the IRS action against              
          their account, she nevertheless filed her 1995 return jointly               
          with Mr. Cowdery.                                                           
          Tax Liability Payments                                                      
               On May 9, 1997, the County Clerk of Pierce County,                     
          Washington, entered a Decree of Dissolution with respect to                 
          petitioner and Mr. Cowdery’s marriage.  The divorce decree stated           
          that Mr. Cowdery was responsible for providing spousal support to           
          petitioner and for paying the IRS liabilities.  Mr. Cowdery,                
          however, consistently failed to make any such payments.                     
               Petitioner received a court judgment against Mr. Cowdery for           
          his failure to make the support and tax liability payments.  On             
          October 28, 1999, the County Clerk of Pierce County, Washington,            
          entered a Judgment for Past Due Spousal Maintenance and Payments            
          Made to IRS, which stated in pertinent part, the following:                 
               3.5   JUDGMENT FOR PAST SPOUSAL MAINTENANCE                            
                         YVONNE LOPEZ shall have judgment against                     
                         THOMAS  COWDERY in the amount of $3,575.00                   
                         for unpaid spousal maintenance for the period                
                         from 6/16/98 through 7/15/99.                                
               3.6   OTHER RECOVERY AMOUNTS                                           
                         YVONNE LOPEZ shall have judgment against                     
                         THOMAS COWDERY for $1,246.32 for the payments                
                         petitioner has made to the IRS.                              
          Despite the judgment, however, petitioner received no money from            
          Mr. Cowdery.  Because of Mr. Cowdery’s failure to pay the income            





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