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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 additional
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