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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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