Alexandra M. Medlin - Page 6

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            income as alimony received and disallowed Burley's and Mary's                               
            claimed deduction.                                                                          
            Medical Insurance Premiums                                                                  
                  Alexandra was covered under the dealership's medical                                  
            insurance policy until 1992 or 1993, when the insurance carrier                             
            informed the dealership that she no longer qualified as an                                  
            insured because she was not its employee.  During 1994, Alexandra                           
            and Burley arranged for the dealership to reimburse Alexandra for                           
            the cost of the premiums for the medical insurance which she had                            
            obtained through her employer.  This arrangement was the least                              
            costly alternative for providing medical insurance for Alexandra.                           
            The dealership issued Burley a Form 1099-DIV for 1994 which                                 
            reflected that he had received a constructive dividend in the                               
            amount of $1,998, the total of the medical insurance premiums                               
            reimbursed by the dealership during 1994.                                                   
                  Alexandra reported the $1,998 as alimony received on her                              
            1994 original return.  She later filed her amended return for                               
            1994 on which she omitted $1,999.3  Burley and Mary claimed an                              
            alimony paid deduction in the amount of $1,998 on their 1994                                
            return.  In the statutory notices of deficiency, respondent                                 
            included the $1,998 in Alexandra's income as alimony received and                           
            disallowed Burley's and Mary's claimed deduction.                                           


            3           This amount represented the previously reported medical                         
            insurance premiums.  Alexandra agrees that the correct amount of                            
            the medical insurance premiums in issue is $1,998.                                          




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