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Addition to Tax Accuracy-Related Penalty
Petitioner Deficiency Sec. 6651(a)(1)1 Sec. 6662(a)
Stephen A. Raymond $13,181 -- --
Sandra C. Raymond 3,964 $198 $793
The issue remaining for decision is whether certain payments
made during 1991 by petitioner Stephen A. Raymond (Mr. Raymond)
to petitioner Sandra C. Raymond (Ms. Raymond)2 constitute alimony
within the meaning of section 71(b) that is deductible by Mr.
Raymond under section 215(a) and that is includible in the income
of Ms. Raymond under section 71(a). We hold that they do.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petitions in these cases were filed, Mr.
Raymond and Ms. Raymond lived separately in Charlestown, Massa-
chusetts, and Carlisle, Massachusetts, respectively. Mr. Raymond
filed his U.S. individual income tax return (return) for 1991 on
May 4, 1992, and Ms. Raymond filed her 1991 return on October 26,
1992.
The Raymonds were married on June 14, 1965, and have two
children, Sonya and Jessica, who were born on November 12, 1970,
and February 27, 1978, respectively. During 1991, Sonya Raymond,
1 All section references are to the Internal Revenue Code in
effect for the year at issue. All Rule references are to the Tax
Court Rules of Practice and Procedure.
2 We shall sometimes refer to Mr. Raymond and Ms. Raymond as the
Raymonds.
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