- 2 - 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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