Thomas A. Schroeder - Page 3




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               Respondent determined a deficiency of $1,043 in petitioner’s           
          Federal income tax for 2003.  Petitioner does not dispute the               
          deficiency but claims that his former spouse should be held                 
          liable for one-half of it.                                                  
                                     Background                                       
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
          Petitioner resided in Indiana at the time that his petition was             
          filed.                                                                      
               During 2003, petitioner was married to Kathi Schroeder.                
          Petitioner and Kathi Schroeder divorced in 2004.                            
               For more than 10 years prior to 2003 and during 2003,                  
          petitioner was a limited partner in Franklin Ridgewood Associates           
          Limited Partnership.  Petitioner made the investment and signed             
          the necessary papers because Kathi Schroeder did not participate            
          in matters involving investments.  On the partnership return,               
          petitioner alone was shown as the partner receiving distributions           
          of income; Kathi Schroeder was not shown as a partner.  During              
          2003, petitioner received distributed income and interest income            
          from Franklin Ridgewood Associates Limited Partnership in the               
          total amount of $2,894.                                                     
               On April 15, 2004, petitioner and Kathi Schroeder filed a              
          joint Form 1040, U.S. Individual Income Tax Return, for 2003.               
          The income of $2,894 received from Franklin Ridgewood Associates            







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