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MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined deficiencies in
petitioners' Federal income taxes and additions to tax as
follows:
Norman and Marcia Spector
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6661(a)
1986 $15,117 $756 2 $3,779
1987 16,043 802 2 3,845
1988 9,580 1479 -- 2,395
Lionel Ehrenworth
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6661(a)
1986 26,005 1,300 2 6,501
1987 20,610 1,031 2 5,153
Lionel and Beth Ehrenworth
Additions to Tax
Year Deficiency Sec. 6653(a)(1) Sec. 6661(a)
1988 11,648 582 2,912
1 Sec. 6653(a)(1) applied in 1988.
2 Fifty percent of the interest due on the portion of the
underpayment attributable to negligence.
Petitioners Marcia Spector and Lionel Ehrenworth were
divorced in 1980. Petitioners filed cross-motions for partial
summary judgment relating to whether payments made by
Dr. Ehrenworth to Mrs. Spector after their divorce were alimony
or a property settlement. We denied both motions. Spector v.
Commissioner, T.C. Memo. 1994-147. We held that whether a
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Last modified: May 25, 2011