Mary Elizabeth Cumings - Page 4




                                        - 3 -                                         
               During 2002, petitioner was married to Robert Parker (Mr.              
          Parker).  In October 2002, petitioner and Mr. Parker separated,             
          and in 2004 they divorced.                                                  
               Mr. Parker was the sole proprietor of two businesses:  Bob’s           
          Drywall and Parker Custom Homes.  During 2002 petitioner was a              
          laborer and a bookkeeper for Mr. Parker’s drywall business.                 
               During their marriage, petitioner and Mr. Parker maintained            
          a joint checking account from which they both paid household                
          bills.  Among other things, petitioner made deposits into the               
          account, wrote checks for household, business, and personal                 
          purposes, reviewed the monthly bank statements, and reconciled              
          the checkbook.  Petitioner also opened the household mail.  After           
          petitioner and Mr. Parker separated in October 2002, petitioner’s           
          access to the joint checking account apparently was restricted.             
               Petitioner and Mr. Parker timely filed a joint Federal                 
          income tax return for 2002.  Their return reflected an unpaid               
          income tax liability of $506.3  The tax liability resulted from             
          an underpayment of self-employment tax arising from Mr. Parker’s            
          sole proprietorships.                                                       






               3The original tax return filed with the Internal Revenue               
          Service (IRS) did not contain the signature page.  Petitioner and           
          Mr. Parker subsequently filed a document confirming that they had           
          signed the return.                                                          





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