Ellen M. Rangos - Page 2

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          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.                                                  








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