Kirk A. Keegan, Jr. - Page 2

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                  Christine V. Olsen, for respondent.                                                 


                                        MEMORANDUM OPINION                                            
                  NIMS, Judge:  Respondent determined a deficiency in the                             
            Federal income tax of Kirk A. Keegan, Jr. (petitioner) for the                            
            tax year ended December 31, 1992, in the amount of $8,698, and an                         
            accuracy-related penalty pursuant to section 6662(a) in the                               
            amount of $1,740.                                                                         
                  All section references are to sections of the Internal                              
            Revenue Code in effect for the year in issue, unless otherwise                            
            indicated.  All Rule references are to the Tax Court Rules of                             
            Practice and Procedure.                                                                   
                  After concessions, the sole remaining issue for decision is                         
            whether petitioner is entitled to a section 215 alimony deduction                         
            in excess of that allowed by respondent for amounts paid for the                          
            support of petitioner's wife, Barbara C. Keegan (Mrs. Keegan).                            
                  This case was submitted fully stipulated, and the facts as                          
            stipulated are so found.  This reference incorporates herein the                          
            stipulation of facts and attached exhibits.  Petitioner resided                           
            in Newport Beach, California, at the time he filed his petition.                          
                                             Background                                               
                  Petitioner requested a legal separation from Mrs. Keegan on                         
            January 27, 1992.  Later that month, petitioner began making                              
            payments of between $4,817 and $9,914 a month to, or on behalf                            
            of, Mrs. Keegan.  An Order to Show Cause scheduled for March 4,                           




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