Edward J. Richardson - Page 2

                                        - 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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