Helen C. Hopkinson - Page 2




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          Unless otherwise indicated all section references are to the                 
          Internal Revenue Code in effect for the years in issue, and all              
          Rule references are to the Tax Court Rules of Practice and                   
          Procedure.                                                                   
               In the instant case, the issues we must decide are:  (1)                
          Whether amounts paid to petitioner, or on her behalf, by her                 
          former husband, Peter S. Hopkinson, and excluded by petitioner               
          from her gross income on her income tax returns for the years in             
          issue are includable in her gross income as alimony; and (2)                 
          whether petitioner is liable for the accuracy-related penalty                
          pursuant to section 6662(a) for the years in issue.                          
                                   FINDINGS OF FACT                                    
               Some of the facts and certain exhibits have been stipulated             
          for trial pursuant to Rule 91.  The parties' stipulations of fact            
          are incorporated by reference and are found as facts in the                  
          instant case.                                                                
               At the time she filed the petition in the instant case,                 
          petitioner resided in Alpharetta, Georgia.                                   
               On October 31, 1992, in anticipation of divorce, petitioner             
          and her former husband entered into a settlement agreement                   
          (settlement agreement).  The relevant parts of the settlement                
          agreement provide:                                                           








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