John L. Seymour - Page 2

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               RUWE, Judge:  Respondent determined deficiencies in                    
          petitioner's Federal income taxes and additions to tax as                   
          follows:                                                                    

                   Additions to Tax                                                   
          Year      Deficiency      Sec. 6651(a)(1)     Sec. 6654(a)                  
          1992       $116,819            $926              $2,910                     
          1993        100,290              --               1,749                     

               After concessions, the issues for decision are: (1) Whether            
          interest petitioner paid to his former spouse pursuant to a                 
          decree of divorce is nondeductible personal interest under                  
          section 163(h)(1);1 and (2) whether petitioner is liable for the            
          additions to tax under section 6654(a) for the taxable years 1992           
          and 1993.                                                                   

                                  FINDINGS OF FACT                                    

               Some of the facts have been stipulated and are so found.               
          The stipulation of facts, supplemental stipulation of facts, and            
          stipulation of settled issues are incorporated herein by this               
          reference.  Petitioner resided in Palm Beach Gardens, Florida, at           
          the time he filed his petition.                                             
               By Final Judgment of Dissolution of Marriage dated July 20,            
          1987 (the divorce decree), the Florida Circuit Court of the                 

               1Unless otherwise indicated, all section references are to             
          the Internal Revenue Code in effect for the taxable years in                
          issue, and all Rule references are to the Tax Court Rules on                
          Practice and Procedure.                                                     




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