- 9 -
and tendered it to Cochran Cadillac as payment for the 1994
automobile.
Petitioner insured Vehicle No. 2 with Allstate Insurance Co.
and paid all insurance premiums; she was named as the loss payee.
Petitioner performed the required maintenance on both Vehicles
No. 1 and 2. Both automobiles had low mileage and were in
excellent condition at the time they were traded in.
Petitioner retained Vehicle No. 2 until 1997 when, pursuant to
Paragraph 12, Mr. Rangos provided her with a new Cadillac DeVille.
Federal Income Tax Returns
On her 1991 return, petitioner excluded from income Mr.
Rangos' $32,733.04 payment to Cochran Cadillac for Vehicle No. 1.
On her 1994 return, petitioner excluded from income Mr. Rangos'
$21,600.97 payment for Vehicle No. 2. Petitioner obtained an
opinion of a law firm which she relied upon in taking these
positions on her returns.
On his 1991 and 1994 returns, Mr. Rangos deducted as alimony
the amounts he paid for Vehicles Nos. 1 and 2 during those years
pursuant to section 215.
Notices of Deficiency
In the notices of deficiency, respondent determined that
petitioner failed to report alimony income of $32,733 and $21,601
for 1991 and 1994, respectively. Respondent has conceded the
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011