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the condition of the residence acreage as of April of 1998, as
follows: “A ranch home reflecting some deferred maintenance,
frankly, a barn, some farm equipment scattered around the barn.”
Pursuant to the above offer of Susan to provide $45,000 for
the purchase of the farm acreage, on July 13, 1998, a written
purchase and sale agreement relating to the farm acreage was
prepared showing Richard and Marilou as the sellers, and Carrie,
Tracy, and Deborah, as the purchasers. Susan’s name does not
appear on this document, and the only signature that appears on
this document is Richard’s. The signature line for Marilou is
blank. On the signature line for Carrie, Tracy, and Deborah, as
buyers, Carrie’s, Tracy’s and Deborah’s names are printed. In
July and August of 1998, Tracy and Deborah were not aware of this
document, and in July of 1998 no payment was made under this
document.
On August 17, 1998, Richard untimely filed his 1995 Federal
income tax return on which he reflected a total Federal income
tax liability of $28,336. No payment was submitted by Richard to
respondent with the filing of this tax return.
On September 9, 1998, generally consistent with the terms of
the above July 13, 1998, purchase and sale agreement relating to
the farm acreage, Richard and Marilou executed a warranty deed
transferring all of the farm acreage to Carrie, Tracy, and
Deborah, as tenants in common, with the exception of 20 acres
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Last modified: May 25, 2011