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seeks a review under section 6330(d) of respondent’s decision to
proceed with collection of petitioner’s portion of a Federal
income tax liability for the 1996 tax year.
Some of the facts were stipulated. Those facts, with the
exhibits annexed thereto, are so found and made part hereof.
Petitioner’s legal residence at the time the petition was filed
was Douglasville, Georgia.
Petitioner and her former husband, Curtis Carlin
(intervenor), were married in December 1995. At that time,
petitioner was 20 and intervenor was 29. They immediately
settled in Florida, where they rented a house. Petitioner has a
high school education and worked as a hair stylist, and
intervenor worked for both Show Tech Support, Inc., and ACC
Productions, Inc., managing props on motion picture sets. In May
1996, petitioner gave birth to a son. As a result, petitioner
worked only intermittently throughout 1996.
Approximately 6 weeks before petitioner’s son was born,
intervenor’s mother (Ms. Carlin) died. Intervenor was the sole
descendant and inherited Ms. Carlin’s estate. Shortly
thereafter, petitioner moved to Georgia with her parents, and
intervenor remained in Florida to settle his mother’s affairs.
Intervenor later joined petitioner in Georgia, where the couple
subsequently purchased land.
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