- 2 - MEMORANDUM OPINION HALPERN, Judge: I. Introduction By notice of deficiency dated July 18, 1996, respondent determined a deficiency in petitioner’s 1993 Federal income tax of $48,275 and an accuracy-related penalty in the amount of $9,655. Each party has conceded certain issues and the issues remaining for decision are (1) the deductibility of $50,000 claimed by petitioner as an alimony payment, (2) the deductibility of $48,651.75 claimed by petitioner as business- related legal fees, (3) whether petitioner must include in gross income $30,000 received by him from Radiology Affiliates of NY, and (4) whether any underpayment is due to petitioner’s negligence or disregard of rules or regulations. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Certain facts have been stipulated. The stipulation of facts filed by the parties, with attached exhibits, is incorporated herein by this reference. We have need to find few facts in addition to those stipulated and, accordingly, shall not separately set forth those findings. We include our additionalPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011