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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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