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RUWE, Judge: Respondent determined the following
deficiencies and additions to tax in petitioners' Federal income
taxes:
John F. and Sarah R. Daugharty
docket No. 6023-95
Year Deficiency
1991 $4,583
1992 8,680
1993 8,406
Faye E. Daugherty
docket No. 6280-95
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1988 $4,701 $1,175 $302
1989 4,568 1,142 309
1990 4,395 1,099 288
1991 4,208 1,052 241
1992 3,967 992 171
1993 3,840 960 160
In order to protect the Government from a potential whipsaw,
respondent has taken inconsistent positions in these dockets.
The issues for decision are: (1) Whether payments made by
petitioner John F. Daugharty to his former spouse, petitioner
Faye E. Daugharty, in the amount of $30,000 per year constitute
alimony or, alternatively, a property settlement; and (2) if we
find that these payments constitute alimony, whether petitioner
Faye E. Daugharty is liable for additions to tax for failure to
file a timely return pursuant to section 6651(a)(1) and failure
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