- 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 year. 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