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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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Last modified: May 25, 2011