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FINDINGS OF FACT
The parties have stipulated some facts, which we incorporate
herein by this reference. When he petitioned the Court,
petitioner resided in Kansas.
Petitioner’s 1995 Tax Reporting
On August 5, 1995, petitioner wed Astrid Downing in what was
to prove a short-lived marriage (they divorced in 1997). About 10
days after the wedding, he and Astrid Downing moved to Singapore,
where he was employed as senior vice president for a U.S.
company, Seagate Technology, Inc.
Petitioner’s and Astrid Downing’s 1995 Federal income tax
reporting, and the IRS’s handling of their accounts, is shrouded
in mystery, confusion, and error. Although Astrid Downing filed
her 1995 return (prepared by H&R Block) on time, for reasons not
disclosed by the record she erroneously listed her filing status
as “Single”, provided a California address (even though
petitioner claims she then resided in Singapore with him), and
used the name “Astrid M Stevenson”, notwithstanding that her name
(according to petitioner’s testimony) was Astrid Downing. On her
1995 return, Astrid Downing claimed a $1,940 overpayment. On May
6, 1996, respondent refunded this amount to her.
1(...continued)
Internal Revenue Code, as amended, and Rule references are to the
Tax Court Rules of Practice and Procedure.
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Last modified: November 10, 2007