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MEMORANDUM OPINION
DINAN, Special Trial Judge: These consolidated cases were
submitted pursuant to the provisions of section 7443A(b)(3) and
Rules 180, 181, and 182.1
Respondent determined a deficiency in petitioner Alexandra
M. Medlin's (Alexandra) Federal income tax for 1994 in the amount
of $1,946. Respondent also determined a deficiency in
petitioners Burley M. Medlin's (Burley) and Mary K. Medlin's
(Mary) Federal income tax for 1994 in the amount of $2,170.
After concessions,2 the issue remaining for decision is
whether the amounts in issue are properly characterized as
alimony or separate maintenance payments within the meaning of
section 71(b).
These cases were submitted fully stipulated under Rule 122.
The stipulations of fact and attached exhibits are incorporated
herein by this reference. Alexandra resided in Charlottesville,
Virginia, and Burley and Mary resided in Williamsburg, Virginia,
1 Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect for the taxable year in
issue. All Rule references are to the Tax Court Rules of
Practice and Procedure.
2 The parties agree that Burley's direct reimbursement of
$784 for Alexandra's medical expenses which were not covered by
her medical insurance constitutes alimony or separate maintenance
payments. As Alexandra points out on brief, she overstated the
amount of such payments on her 1994 original and amended returns
by $19 ($803 - $784).
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Last modified: May 25, 2011