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incorporated herein by reference. At the time the petition was
filed, petitioner’s legal residence was Brownstown, Michigan.
Intervenor resided in Flat Rock, Michigan, at the time of the
filing of the Notice of Intervention.
Petitioner and intervenor married on or about February 14,
1989. During part of the year at issue, petitioner and
intervenor were married and living together. They did not,
however, reside together during the entire year. They legally
separated sometime in August 2002, and their divorce was
finalized on May 22, 2003. Neither the divorce decree nor the
marital separation agreement allocates or addresses
responsibility for payment of debts.
Petitioner was employed as a maintenance supervisor by
Daimler-Chrysler during the year at issue. He received taxable
wages of $124,799 in 2002. Intervenor operated a real estate
appraisal business during this time. She received $72,855 in
nonemployee compensation for her work as an appraiser.
Despite their recent divorce, petitioner and intervenor
mutually agreed to file jointly a Form 1040, U.S. Individual
Income Tax Return, for 2002. The return was prepared, as it had
been done frequently in the past, by petitioner. He reported the
income from his employment with Daimler-Chrysler and reported the
income and expenses of intervenor’s business activity on a
Schedule C, Profit or Loss From Business. Petitioner relied on
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