- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011