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During 1993, the following amounts were received from or
paid on petitioner's behalf by her former husband: (1) $12,000
($1,000 per month for 12 months), as reimbursement for attorney's
fees; (2) $5,201.81, to reimburse her for tuition and college
expenses she paid personally; and (3) $3,520, paid as tuition to
Oglethorpe University.
During 1994, the following amounts were received or paid on
petitioner's behalf by her former husband: (1) $12,000 ($1,000
per month for 12 months), as reimbursement for attorney's fees;
(2) $3,015.91, to reimburse her for tuition and college expenses
which she paid personally; and (3) $8,678.50, paid as tuition to
Oglethorpe University.
The payments described above were received directly by
petitioner, or paid on her behalf, in cash or by check and were
paid pursuant to the divorce decree and settlement agreement.
During the years in issue, petitioner did not live in the
same household as her former husband and did not file a joint
income tax return with her former husband.
On November 14, 1994, petitioner filed a Form 1040 for
taxable year 1993. For the 1994 taxable year, petitioner timely
filed a Form 1040.
On February 20, 1997, respondent issued two notices of
deficiency determining unreported income in the amounts of
$28,383 for taxable year 1993 and $45,786 for taxable year 1994.
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