Ruth E. Neal - Page 8

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          problems, petitioner, with their three children, left the marital             
          home.  Petitioner and Alimam were divorced on April 14, 1998.                 
               In the divorce decree of the Superior Court of Columbia                  
          County, State of Georgia, Alimam was ordered to pay all                       
          outstanding joint Federal income taxes “as well [as] any other                
          future tax liability having been incurred during the course of                
          the parties’ marriage”.                                                       
               In the divorce proceeding, petitioner was not awarded                    
          alimony or any support payments from Alimam.  Alimam was ordered              
          to pay monthly child support of $3,000 for the three children,                
          which child support Alimam paid only sporadically.  Alimam was                
          once incarcerated for failure to pay such child support.                      
               Throughout their marriage and in spite of petitioner’s                   
          requests, Alimam did not provide to petitioner any financial                  
          information relating to his medical practice, and petitioner was              
          never shown any books and records relating to Alimam’s medical                
          practice.                                                                     
               During the years in issue, all of petitioner’s annual income             
          and her withheld taxes were reflected on Forms W-2, Wage and Tax              
          Statement, which petitioner gave to Alimam each year prior to the             
          preparation by Alimam’s accountant of their joint Federal income              
          tax returns.  The taxes withheld from petitioner’s salary each                
          year reflected essentially the total Federal income tax                       








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