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payments and that no income taxes had been withheld from wages or
salary on their behalf.2
All of the reported income on petitioner and John’s 1995
joint Federal income tax return, with the exception of a small
amount of interest income, consisted of income from MGI. On the
above tax return and on related Schedules K-1, Shareholder’s
Share of Income, Credits, Deductions, etc., MGI’s reported income
was reflected as allocable equally to petitioner and to John.
Petitioner was generally aware of the $24,050 interest
deductions on the mortgages and the $109,742 MGI income that were
reflected on her and John’s 1995 joint Federal income tax return.
From October of 1996 through December of 1997, with joint
marital assets, petitioner and John made 13 additional payments
totaling $11,657 on their $17,516 underpayment for 1995.
On January 13, 1998, after an audit of petitioner and John’s
1995 joint Federal income tax return, respondent mailed to
2 Also mailed to respondent with petitioner and John’s 1995
joint Federal income tax return was a $1,000 partial payment
toward the $17,516 balance due reflected on the return. As a
result, the amount of petitioner and John’s 1995 tax underpayment
apparently should be $16,516. Both parties, however, have
treated the entire $17,516 balance due as the underpayment. For
convenience herein, we refer to the underpayment amount as
$17,516 and leave any modification thereof to the parties’ Rule
155 computation. Further, with their 1995 tax return and the
$1,000 payment, petitioner and John mailed to respondent an
additional $7,235 check reflecting the balance due on their then
outstanding 1993 joint Federal income taxes, and petitioner and
John made a request to pay in installments the remaining $16,516
balance due on their 1995 income tax liability.
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