- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011