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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 a
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