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amounts of deficiencies and accuracy-related penalties now at issue
are:
Penalty
Year Deficiency Sec. 6662(a)
1992 $75,707 $15,141
1993 97,891 19,578
1994 54,793 10,959
The issues remaining for decision are: (1) Whether payments of
$240,000 Monte H. Goldman made to Sally Parker during each year in
issue were properly deductible as alimony, and (2) whether a
section 6662(a) accuracy-related penalty is applicable to each year
in issue.
All section references are to the Internal Revenue Code, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulation of
facts is incorporated in our findings by this reference.
Monte H. Goldman resided in Colorado on January 10, 1995, the
date of his death. Carole Schutter (formerly Carole Goldman), the
personal representative of the Estate of Monte H. Goldman
(hereinafter referred to as petitioner), resided in Colorado at the
time the petition was filed.
On July 31, 1974, Mr. Goldman and Sally Goldman (presently
known as Sally Parker and hereinafter referred to as Ms. Parker)
married. They had two children, one born in 1978 and a second in
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