- 15 -
On October 5 and on November 9, 1998, respondent assessed
the above Federal income tax liabilities that Richard had
reflected on his late-filed Federal income tax returns for 1995
and 1996 ($28,336 and $20,238, respectively) and penalties
associated therewith, for total taxes and penalties assessed for
both years of $70,724, not including interest.
On approximately January 20, 1999, respondent’s revenue
officer investigated Richard’s credit standing, met again with
Richard, updated Richard’s financial statement, and reviewed
documents relating to Richard’s and Marilou’s divorce. On the
updated financial statement, Richard reflected monthly income of
zero, $1,000 in cash assets, and no other savings.
Throughout 1998 and 1999, and until May of 2000, and in
spite of the above 1998 transfer of the residence acreage to
Carrie and Marilou, Richard continued to live rent free in the
home located on the residence acreage.
On or about May 10, 2000, Marilou and Carrie sold the
residence acreage to an unrelated third party for a total sales
price of $80,000. Of the net sales proceeds, Marilou received
approximately $51,803 (relating to the $50,000-plus still due her
under the 1994 divorce decree, which in turn related to her
interests in the two parcels of real property), and Carrie
received approximately $16,894 in cash, plus Carrie received (by
deed from Marilou) Marilou’s one-half interest in the 20-acre
Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 NextLast modified: May 25, 2011