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occurred involving the farm acreage and the residence acreage,
nor what consideration was associated therewith.
On September 28, 1998, Richard untimely filed his 1996
Federal income tax return, on which was reflected a total Federal
income tax liability of $20,238. With this tax return, no
payment was submitted by Richard to respondent.
Almost all of the income reflected on Richard’s 1995 and
1996 Federal income tax returns was attributable to the taxable
distributions from Richard’s IRA account ($98,500 in 1995 and
$70,500 in 1996).
On September 28, 1998, Richard prepared and signed and gave
to respondent’s revenue officer a financial statement,
Form 433-A, Collection Information Statement for Individuals,
relating to Richard’s financial assets, on which it was indicated
that Richard was employed part-time as a construction worker for
which Richard earned an average of $1,032 a month, that Richard’s
monthly personal living expenses were $1,060, that he had only
$10.27 in a bank account, that he owned no real property, that
his assets had a total value of only $8,885, and that Richard had
total liabilities of $93,352 (including the remaining $50,000 to
which Marilou was entitled under the divorce decree and not
including any Federal income taxes, penalties, and interest owed
to respondent).
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