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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.
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