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All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
The issues for consideration are: (1) Whether amounts paid
by petitioner to his former wife in 1989 and 1990 were alimony;1
(2) whether petitioner was entitled to a deduction for Schedule C
interest expense for his 1989 taxable year in excess of that
allowed by respondent; (3) whether petitioner is liable for an
addition to tax under section 6651(a)(1) for the taxable year
1989; and (4) whether petitioner is liable for the accuracy-
related penalty under section 6662 with respect to the
underpayment of tax resulting from deducting interest expense in
excess of that allowed by respondent.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
herein by this reference. Petitioner resided in Pineville,
Pennsylvania, at the time the petition was filed in this case.
Petitioner Robert J. Sugarman is an attorney. Petitioner
and M. Colleen Sugarman (Colleen) were married on April 30, 1983.
Subsequent to their marriage, petitioner and Colleen purchased
1 All references to alimony mean alimony as defined by sec.
71(b) of the Internal Revenue Code unless otherwise indicated.
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