- 2 - MEMORANDUM OPINION NIMS, Judge: This matter is before the Court on respondent's motion, and petitioners' cross-motion, for partial summary judgment filed pursuant to Rule 121 on August 28, 1997, and September 29, 1997, respectively. Unless otherwise indicated, all section references are to sections of the Internal Revenue Code in effect for the years at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. Respondent determined the following deficiencies and accuracy-related penalties with respect to the Federal income tax of petitioners, Dewey and Carlena K. Hammond, for the taxable years 1993, 1994, and 1995: Penalty Year Deficiency Sec. 6662(a) 1993 $9,888 $1,978 1994 9,028 1,806 1995 7,339 1,468 As a result of concessions made subsequent to the motion and cross-motion for partial summary judgment, the parties now agree that this case may be resolved in its entirety via summary judgment. The sole remaining issue for decision is whether certain monthly payments of $2,000 made by Dewey Hammond (herein Dewey or petitioner) to his former spouse, Rebecca Hammond (Rebecca), during each of the years in issue pursuant to aPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011