Dewey and Carlena K. Hammond - Page 2

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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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