Richard M. Downing - Page 2

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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.                            

          Internal Revenue Code, as amended, and Rule references are to the           
          Tax Court Rules of Practice and Procedure.                                  

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