- 2 - 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:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011