T.C. Memo. 1998-455
UNITED STATES TAX COURT
ALEC JEFFREY MEGIBOW, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22268-96. Filed December 28, 1998.
At issue are (1) the deductibility of $50,000
claimed by P as an alimony payment, (2) the
deductibility of $48,651.75 claimed by P as business-
related legal fees, (3) whether P must include in gross
income $30,000 received by him from his employer, and
(4) whether any underpayment is due to P’s negligence
or disregard of rules or regulations.
Held, the $50,000 payment is not alimony; P has
failed to prove that his obligation to make that
payment would not survive the death of his ex-spouse.
Held, further, P has failed to prove that the legal
fees are either alimony or otherwise deductible. Held,
further, P has failed to prove that the payment from
his employer was other than taxable compensation.
Held, further, P has failed to prove that he neither
was negligent nor disregarded rules or regulations.
Anthony M. Bentley, for petitioner.
Donald E. Edwards, for respondent.
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