Ellen M. Rangos - Page 9

                                        - 9 -                                         

          and tendered it to Cochran Cadillac as payment for the 1994                 
          automobile.                                                                 
               Petitioner insured Vehicle No. 2 with Allstate Insurance Co.           
          and paid all insurance premiums; she was named as the loss payee.           
               Petitioner performed the required maintenance on both Vehicles         
          No. 1 and 2.  Both automobiles had low mileage and were in                  
          excellent condition at the time they were traded in.                        
               Petitioner retained Vehicle No. 2 until 1997 when, pursuant to         
          Paragraph 12, Mr. Rangos provided her with a new Cadillac DeVille.          
          Federal Income Tax Returns                                                  
               On her 1991 return, petitioner excluded from income Mr.                
          Rangos' $32,733.04 payment to Cochran Cadillac for Vehicle No. 1.           
          On her 1994 return, petitioner excluded from income Mr. Rangos'             
          $21,600.97 payment for Vehicle No. 2. Petitioner obtained an                
          opinion of a law firm which she relied upon in taking these                 
          positions on her returns.                                                   
               On his 1991 and 1994 returns, Mr. Rangos deducted as alimony           
          the amounts he paid for Vehicles Nos. 1 and 2 during those years            
          pursuant to section 215.                                                    
          Notices of Deficiency                                                       
               In the notices of deficiency, respondent determined that               
          petitioner failed to report alimony income of $32,733 and $21,601           
          for 1991 and 1994, respectively.  Respondent has conceded the               







Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next

Last modified: May 25, 2011