- 2 - Marie Croteau (Ms. Croteau) deductible for that year as alimony or separate maintenance payments under section 215(a)?1 We hold that they are not. (2) Is petitioner liable for 1993 for the accuracy-related penalty under section 6662(a)? We hold that he is. FINDINGS OF FACT Some of the facts have been stipulated and are so found. Petitioner resided in Whitefish, Montana, at the time the petition was filed. Petitioner married Ms. Croteau in May 1981. They separated in November 1992. On January 13, 1993, petitioner and Ms. Croteau executed a marital settlement agreement (agreement) which petitioner had prepared. In preparing the agreement, petitioner used as a model a marital settlement agreement that had been entered into by his son and the former wife of his son. On January 15, 1993, Mr. Croteau filed a petition in the Superior Court of California, county of Ventura, for dissolution of his marriage to Ms. Croteau (petition for dissolution of marriage). The petition for dissolution of marriage was a preprinted form on which Mr. Croteau provided certain information requested by the form. That preprinted form stated, inter alia: 1 Unless otherwise indicated, 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011