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When notified of the instant Court proceeding, Alimam did
not intervene, and Alimam does not challenge petitioner’s
eligibility for equitable relief from joint and several
liability. Alimam was not called as a witness at trial. As of
the time of trial, petitioner no longer has contact with Alimam,
and Alimam apparently is no longer licensed to practice medicine.
Reflected in the table below, for the years at issue, are
comparisons of petitioner’s and of Alimam’s separate earned
income, estimates of petitioner’s and of Alimam’s “separate”
Federal income tax liabilities, and the Federal income tax
payments that were made for each year (reflecting primarily
petitioner’s withheld taxes), as well as the total amount of
petitioner and of Alimam’s joint Federal income tax liability
reported on the tax returns and not challenged by respondent.
Amounts estimated for the “separate” (sep.) tax liabilities of
petitioner and of Alimam are based on respondent’s computations
of the portions of petitioner and of Alimam’s total joint Federal
income taxes for 1993, 1994, and 1995 that are attributable
separately to petitioner and to Alimam.
Petitioner Alimam Joint
Earned Est. sep.Tax Earned Est. sep.Tax total tax
Year income tax liab.payments income tax liab.payments liability
1993 $110,163 $21,987$20,302 $154,316 $51,004 0 $72,991
1994 116,759 23,45921,711 106,180 29,443 0 52,902
1995 122,693 25,19423,221 78,310 18,066 0 43,260
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