- 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 andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011