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Their separation agreement, dated March 12, 2002, stated, in
pertinent part:
The parties currently owe the IRS approximately
$11,000.00 due to Husband’s failure to pay his Social
Security tax. Husband agrees that he shall be solely
responsible for the said debt to the IRS and that he
shall pay the debt to the IRS in a timely fashion and
as determined by the IRS.
Petitioner and Mr. Puckett were divorced in March 2003. They
have one son, who is hearing impaired and resides with
petitioner. Petitioner was not abused by Mr. Puckett.
During 2000, petitioner worked part-time as a nurse for
Novant Health Corporate Presbyterian Hospital. Petitioner earned
wages of $4,206 from which $44 was withheld as Federal income
tax.
During 2000, petitioner also operated a retail clothing
business known as Ensembles, Inc. (Ensembles). She and Mr.
Puckett were joint owners of Ensembles, through an S corporation
that they organized in August 1999. During 2000, Ensembles
incurred substantial losses and eventually closed for business in
June 2001.
Mr. Puckett was also self-employed as a consultant for
Crothall Health Care, Inc., during 2000. In 2000, he made
estimated tax payments of $38 and reported a net profit of
$62,936 on Schedule C, Profit or Loss From Business.
During 2000, petitioner and Mr. Puckett maintained joint
checking and savings accounts into which they deposited their
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