Tracie Young - Page 19

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              Petitioner contends that she did not know and had no reason             
         to know that Mr. Glaze did not report his wage income received               
         from Mayflower.                                                              
              However, as previously stated, petitioner voluntarily signed            
         the 1995 joint return and admitted that she did review the joint             
         return before filing.  Petitioner and Mr. Glaze maintained a                 
         joint checking account.  Both petitioner and Mr. Glaze deposited             
         their respective income into said joint checking account.                    
         Petitioner occasionally reviewed the bank statements regarding               
         their joint checking account.  Petitioner personally used moneys             
         from the joint checking account to pay household expenses.                   
         Further, petitioner knew that Mr. Glaze drove a truck for                    
         Mayflower and knew he was receiving wage income from Mayflower.              
         Also, the interest income from the U.S. Treasury was received in             
         both petitioner’s and Mr. Glaze’s names.  Thus, petitioner knew              
         or had reason to know of the unreported income which gave rise to            
         the taxable year 1995 deficiency, addition to tax pursuant to                
         section 6651(a)(1), and the accuracy-related penalty pursuant to             
         section 6662.  This factor favors denying relief to petitioner.              
         5.  Nonrequesting Spouse’s Legal Obligation                                  
              As previously noted, petitioner and Mr. Glaze were divorced             
         on May 26, 1999, and a divorce decree was entered by the Circuit             
         Court of Shelby County, Tennessee.  The divorce decree refers to             
         a “written Marital Dissolution Agreement” which provides for a               

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