- 2 -
Additions
to Tax Penalty
Sec. Sec.
Year Deficiency 6661 6662(b)(2)
1988 $72,896 $17,624 --
1989 275,897 -- $55,131
1990 82,904 -- 16,581
In the notice of deficiency, respondent determined deficiencies
in and additions to petitioner Irene E. Richardson's (hereinafter
Irene) Federal income taxes in the following amounts:
Additions to Tax Penalty
Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6661(a) 6662(a)
1988 $42,035 $10,509 $10,509 --
1989 84,808 -- -- $16,962
1990 96,782 -- -- 19,356
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
After concessions, the issues for decision all relate to the
nature of payments by Edward to his former spouse, Irene.
Specifically, we must decide: (1) Whether certain payments made
by Edward to his former spouse in the taxable years 1988, 1989,
and 1990 are properly deductible by him under section 215(a);
(2) whether such payments are properly includable as income by
Irene under section 71(a); (3) whether Edward is entitled to a
refund for 1988 or 1990; (4) whether Edward is liable for
additions to tax under section 6661 for the taxable year 1988 and
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Last modified: May 25, 2011