- 2 - Ronald J. Murphy, pro se. Elainie Honjas, for petitioner in docket No. 8531-94. Matthew R. Kretzer and Barbara Leonard, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION HALPERN, Judge: These cases have been consolidated for trial, briefing, and opinion because they involve a common question of fact and law: viz, whether payments made by petitioner Ronald J. Murphy (Ronald Murphy) to petitioner Diane D. Murphy (Diane Murphy), his ex-wife, constitute alimony for purposes of the Federal income tax. In the notices of deficiencies and in her pleadings, respondent has taken inconsistent positions, disallowing alimony deductions to Ronald Murphy but requiring Diane Murphy to report alimony income. Respondent, however, does not ask us to sustain her inconsistent positions. Respondent is content that we determine the tax consequences of the subject payments (the marital payments) consistently between petitioners. Respondent has determined both deficiencies in income tax and accuracy related penalties against Ronald Murphy. Those amounts are as follows: Penalty under Year Deficiency Sec. 6662 1990 $15,180 $3,036 1991 16,509 3,302Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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