Tracie Young - Page 5

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          received the refund in full, and petitioner used the moneys from            
          the refund to pay joint household liabilities.                              
               Petitioner and Mr. Glaze’s 1995 joint income tax return was            
          prepared by Jackson Hewitt Tax Service.  Petitioner “took all the           
          information from my [petitioner’s] tax return from Scottish Rite            
          Hospital, and the information that he [Mr. Glaze] had given me              
          from his tax returns” to the Jackson Hewitt Tax Service Center.             
          Petitioner reviewed the 1995 joint income tax return before                 
          filing it with the Internal Revenue Service.  Both petitioner and           
          Mr. Glaze voluntarily signed their 1995 joint income tax return.            
               On November 21, 1997, respondent issued petitioner and Mr.             
          Glaze a notice of deficiency for taxable year 1995, in which                
          respondent determined that they had unreported income of $36,424            
          and were liable for an income tax deficiency of $8,237, an                  
          addition to tax pursuant to section 6651(a)(1) of $1,493, and an            
          accuracy-related penalty pursuant to section 6662 of $1,647.                
          Neither petitioner nor Mr. Glaze filed a petition with this Court           
          with respect to the notice of deficiency.  Accordingly, on or               
          about April 6, 1998, respondent assessed the tax liability,                 
          addition to tax, and the accuracy-related penalty that were                 
          reflected in the notice of deficiency for taxable year 1995.                
               Petitioner and Mr. Glaze were divorced on May 26, 1999, by a           
          divorce decree entered by the Circuit Court of Shelby County,               
          Tennessee.  The divorce decree refers to a “written Marital                 

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