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joint Federal income tax liabilities relating to 1994 and 1996,
and if so, whether respondent abused his discretion in denying
petitioner a refund relating to 1994 and 1996.
FINDINGS OF FACT
On November 8, 1978, Thomas and Diana Stroud were married.
On May 19, 1980, Mr. and Mrs. Stroud created the Stroud Family
Trust (trust) in which they were the cotrustors, cotrustees, and
cobeneficiaries. On June 29, 1981, Mr. and Mrs. Stroud conveyed
their residence, located at 3856 Montego Drive, Huntington Beach,
California (residence), to the trust.
On or about October 19, 1995, Mr. and Mrs. Stroud filed a
joint Federal income tax return relating to 1994 in which they
reported, but failed to pay, a $36,543 tax liability. On
November 20, 1995, respondent assessed the $36,543 liability but
did not issue a notice of deficiency. On June 21, 1996,
respondent filed a notice of Federal tax lien, relating to the
1994 liability, against the residence.
On April 15, 1997, Mr. and Mrs. Stroud filed a joint Federal
income tax return relating to 1996 in which they reported, but
again failed to pay, a $48,939 tax liability. On June 9, 1997,
respondent assessed the $48,939 liability, but did not issue a
notice of deficiency. On December 4, 1997, respondent filed a
notice of Federal tax lien, relating to the 1996 liability,
against the residence.
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