Dewey and Carlena K. Hammond - Page 4

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               time of remarriage of REBECCA HAMMOND, whichever comes                 
               first.  [Emphasis added.]                                              
               The payments designated for child support in paragraph 1 of            
          the Judgment were modified pursuant to an August 13, 1993, order            
          of the Superior Court of Floyd County, Georgia.  The semimonthly            
          payments were increased to $1,006.25, or $2,012.50 per month.               
               At all times during the years in dispute, petitioner made              
          alimony and child support payments in accordance with the terms             
          of the Judgment by separate check.  Each check was clearly marked           
          either "alimony" or "child support" on its bottom left corner.              
               Petitioners jointly filed Forms 1040, U.S. Individual Income           
          Tax Return, for taxable years 1993, 1994, and 1995.  Petitioners            
          deducted as alimony on each return the total yearly payments of             
          $24,000 made to Rebecca pursuant to the terms of paragraph 2 of             
          the Judgment.  Respondent disallowed these deductions in their              
          entirety.                                                                   
               In addition to the foregoing and the adjustments conceded by           
          petitioners, respondent determined that petitioners were liable             
          for accuracy-related penalties for negligence pursuant to section           
          6662(a) for those years.  During a telephone conference call                
          between the parties and the Court held on October 10, 1997,                 
          respondent conceded that petitioners are not liable for the                 
          section 6662(a) accuracy-related penalties for the years in                 
          dispute.                                                                    







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