- 2 - Addition to Tax and Penalties Year Deficiency Sec. 6651(a) Sec. 6662(a) 1991 $10,147 --- $2,029 1994 6,056 $268 1,211 Unless otherwise indicated, all section references are to the Internal Revenue Code for the years under consideration. All Rule references are to the Tax Court Rules of Practice and Procedure. These cases were consolidated for trial, briefing, and opinion. Following concessions by respondent, the issue remaining for decision concerns the characterization (alimony, as respondent contends, or a property settlement, as petitioner contends) of payments made by petitioner's former husband for the purpose of providing petitioner with an automobile in 1991 and 1994. If the payments are determined to be alimony, then they are taxable to petitioner; if they are determined to be in the nature of a property settlement, then they are nontaxable. FINDINGS OF FACT Some of the facts have been stipulated and are found accordingly. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time she filed her petitions, petitioner resided in Monroeville, Pennsylvania.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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