Vernon Stacy Taylor - Page 4

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          petitioner, although he received wages of $26,850, reported from            
          Archive a net loss of $14,840.  The return also reported net                
          rental income of $2,852 and small amounts of interest and                   
          dividends.                                                                  
               Petitioner and intervenor reported their income yearly on              
          jointly filed Federal income tax returns beginning in 1984, the             
          year of their marriage.  In 1999, wage withholdings were                    
          sufficient to pay the joint tax liability; intervenor’s business            
          interests lost money while petitioner’s business was profitable.            
               For several months leading to the departure of intervenor              
          from the marital household on June 15, 2001, the marriage had               
          been strained and tense.  Despite the “unfriendly” separation,              
          petitioner volunteered to intervenor to prepare a joint income              
          tax return for 2001, as he had done over the course of their                
          marriage.  Intervenor provided petitioner with the information              
          concerning her tax matters for 2001.                                        
               Petitioner signed the return on April 11, 2002, and                    
          presented it to intervenor for her signature.  On the advice of             
          her attorney, intervenor refused to sign the return.  Petitioner            
          filed the return without intervenor’s signature and without                 
          remittance.  Intervenor has, however, ratified the filing of the            
          return on her behalf, but the tax remains unpaid.                           
               Petitioner and intervenor’s divorce is pending in a Texas              
          family court.                                                               






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