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By stipulation, respondent conceded a portion of the deficiency
as determined in the statutory notice of deficiency.
The amount unreported income remaining in dispute for 1993
is $20,721.81, which includes $12,000 paid by petitioner's former
husband as attorney's fees pursuant to paragraphs 4.01 and 11.01
of the settlement agreement and $8,721.81 paid by petitioner's
former husband as tuition pursuant to paragraph 5.01 of the
settlement agreement. The $8,721.81 tuition payment includes
$3,520 paid as tuition directly to Oglethorpe University on
behalf of petitioner and $5,201.81 paid to petitioner to
reimburse her for tuition and college expenses she paid
personally.
The amount of unreported income remaining in dispute for
taxable year 1994 is $23,691.41, which includes $12,000 paid by
petitioner's former husband as attorney's fees pursuant to
paragraphs 4.01 and 11.01 of the settlement agreement and
$11,694.41 paid as tuition pursuant to paragraph 5.01 of the
settlement agreement. The $11,694.41 tuition payment includes
$8,678.50 paid as tuition directly to Oglethorpe University on
behalf of petitioner and $3,015.91 paid to petitioner to
reimburse her for tuition and college expenses she paid
personally.
Respondent further determined that petitioner was liable,
pursuant to section 6662(a), for an accuracy-related penalty in
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