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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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