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rejecting petitioner’s offer to compromise his 1992 income tax
liability.
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 City, Missouri.
Prior Deficiency Proceeding
On October 20, 1997, respondent sent petitioner a notice of
deficiency with respect to income taxes for the years 1992 and
1993. Petitioner timely petitioned this Court, seeking a
redetermination of the deficiencies and additions to tax. On
February 24, 1999, pursuant to the parties’ stipulation, this
Court entered its decision that for taxable year 1992 petitioner
had a deficiency of $44,948 and owed an $8,990 penalty pursuant
to section 6662(a).2
Petitioner’s Marital Settlement
On December 19, 2001, petitioner and his former wife, DeAnna
Daniels Kerr (Ms. Kerr), filed a marital settlement and
separation agreement (the marital settlement) with the Circuit
Clerk, Cass County, Missouri. The marital settlement provided
for the division between petitioner and Ms. Kerr of personal
property, real estate, and financial assets. The marital
2 The Court decided that petitioner had no deficiency and
owed no penalties for his taxable year 1993.
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