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incorporated herein by this reference.2 At the time the petition
was filed, petitioner resided in Santa Rosa, California.
Petitioner previously was employed as an ironworker. He was
injured on the job in 1991, became disabled, and was unable to
return to work. Petitioner received a disability pension from
CFITF. According to a statement from CFITF, petitioner received
$1,435.86 per month, plus two bonus checks, for a total annual
payment of $20,102. According to the terms of the disability
pension, payments would cease if petitioner were to return to
work.
During the year in issue, petitioner lived with his
girlfriend, Lupe Chitwood. The record is unclear as to whether
Ms. Chitwood worked during the year 2000. Ms. Chitwood received
a disability pension during at least part of the year 2000. Ms.
Chitwood sometimes gambled with petitioner, but the record is
unclear as to her winnings and losses during the year in issue.
On April 24, 1995, Jackson issued an annuity policy naming
petitioner as the owner. Petitioner paid $50,000 for the policy.
The anticipated maturity date was April 24, 2007. During the
taxable year 2000, petitioner received a distribution of $8,000
from Jackson. Respondent received an information document from
2 At the end of trial, the Court kept the record open to
permit petitioner to produce an additional document relating to a
distribution from Jackson National Life Ins. Co. When the
document was received, the Court admitted the document into
evidence and closed the record.
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