Norman D. Peterson - Page 5

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               Prior to the entry of the Judgment, Marta received $63,170             
          (10 bimonthly payments of $6,317) from Norman in compliance with            
          the terms of the Tentative Decision as incorporated into the                
          Minute Order.  In addition, Norman made a total of $82,121 in               
          bimonthly spousal support payments to Marta during the period               
          from June 9, 1992, through December 31, 1992.                               
               Norman timely filed a Form 1040, U.S. Individual Income Tax            
          Return, for taxable year 1992.  Norman claimed as a deduction on            
          Line 29, "Alimony paid", of his return the entire amount of                 
          spousal support he remitted to Marta during that year--$145,291.            
               Marta also timely filed a Form 1040 for 1992.  On her                  
          return, Marta reported as income on Line 11, "Alimony received",            
          only that portion of spousal support that she received after the            
          entry of the Judgment--$82,121.                                             
               In the role of a stakeholder, respondent issued separate               
          notices of deficiency to Norman and Marta on May 21, 1996,                  
          addressing petitioners' inconsistent treatment of the support               
          payments made prior to the entry of the Judgment.  Among other              
          adjustments, in the notice issued to Norman, respondent                     
          disallowed the deduction of $63,170 as alimony paid.  In the                
          Explanation attached to the notice of deficiency, respondent                
          stated that Norman had neither established that such amount was             
          alimony, nor that such amount was paid.                                     
               In the notice of deficiency issued to Marta, among other               
          adjustments, respondent determined that the $63,170 of payments             

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Last modified: May 25, 2011