Larry Wade Human - Page 2

                                        - 2 -                                         
               6662(a), I.R.C.  Sec. 6664(c)(1), I.R.C.; sec. 1.6664-                 
               4(b)(1), Income Tax Regs.                                              

               Larry Wade Human, pro se.                                              
               Clinton M. Fried, for respondent.                                      

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               NIMS, Judge:  Respondent determined a deficiency in                    
          petitioner Larry Wade Human's Federal income tax for his 1992               
          taxable year in the amount of $272,222.  Respondent further                 
          determined that petitioner is liable for an accuracy-related                
          penalty for negligence or disregard of rules or regulations                 
          pursuant to section 6662(a) in the amount of $54,444 for that               
               Unless otherwise indicated, all section references are to              
          sections of the Internal Revenue Code in effect for the year at             
          issue.  All Rule references are to the Tax Court Rules of                   
          Practice and Procedure.                                                     
               The issues for decision are as follows:  (1) Whether the               
          payments of $971,684 made to or on behalf of petitioner's former            
          spouse, Anita C. Human (Anita), constitute alimony within the               
          meaning of section 71 so as to be deductible by petitioner                  
          pursuant to section 215(a); and (2) whether petitioner is liable            
          for the section 6662(a) accuracy-related penalty.                           

Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011