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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 3,302
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