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Federal income tax liabilities for 1996, 2000, 2001, 2002, and
2003, representing a cumulative total of $44,383.1
Unless otherwise indicated, all section references are to
the sections of the Internal Revenue Code applicable to this
collection action, and all Rule references are to the Tax Court
Rules of Practice and Procedure.
Background
The facts of this case have been submitted fully stipulated
under Rule 122 and are so found.
Petitioner is a resident of Oregon. Petitioner has been
employed as a nurse for many years.
In 2001, petitioner was divorced from her husband of
8 years.
As part of the divorce from her husband and separation of
their marital property, in 2001 petitioner was to receive assets
with a value of $26,480, including an interest in real property
located at 400 Lake Street, Berrien Springs, Michigan (the
Michigan property). The interest had a value of $25,000 to
petitioner, as specified by the divorce court.
The June 6, 2001, judgment in dissolution of petitioner’s
marriage expressly awarded to petitioner “all the parties’
1 Petitioner’s OIC also related to additional outstanding
Federal income tax liabilities petitioner owed for 1995 but which
are not otherwise involved in this case.
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Last modified: March 27, 2008