- 15 - support and property from her former husband. Petitioner also submitted, as attachments to her briefs, various documents relating to action she has taken against her former husband pursuant to the divorce. Although such documents are not a part of the record, they tend to show that petitioner is pursuing relief against her former husband in the State courts, which is the proper forum for such disputes. Under the circumstances of the instant case, petitioner has not shown that she should not be held to the clear and unambiguous provisions of the settlement agreement and their resulting income tax consequences. As we stated above, petitioner must include the tuition and attorney's fees payments in her gross income. Accuracy-Related Penalty In the notice of deficiency, respondent determined that petitioner was liable for an accuracy-related penalty in the amounts of $1,533 for 1993 and $2,241 for 1994. On brief, respondent concedes that petitioner is not liable for the portion of the accuracy-related penalty that relates to the tuition payments, made by her former husband, during the years in issue. Respondent, however, contends that petitioner is liable for an accuracy-related penalty, with respect to the deficiency from the attorney's fees payments which she excluded from income during the years in issue.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