Irv C. Jaffe - Page 2




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          COUVILLION, Special Trial Judge:  These consolidated cases                  
          were heard pursuant to section 7443A(b)(3)1 and Rules 180, 181,             
          and 182.                                                                    
          Respondent determined a deficiency of $2,775 in the 1994                    
          Federal income tax of petitioner Irv C. Jaffe (Mr. Jaffe) and a             
          deficiency of $3,431 in the 1994 Federal income tax of petitioner           
          Arlene K. Jaffe (Ms. Jaffe).  In an answer to Mr. Jaffe's                   
          petition, respondent asserted an increased deficiency for                   
          unreported dividend income of $11,497.31 from a money market                
          account held jointly by Mr. Jaffe and Ms. Jaffe.  Respondent also           
          asserted, in an answer to Ms. Jaffe's petition, an increased                
          deficiency for unreported dividend income of $15,543 from the               
          same money market account.                                                  
          The issues for decision are:  (1) Whether $18,500 received                  
          by Ms. Jaffe during 1994 constitutes alimony or separate                    
          maintenance payments includable in her income under section 71              
          and deductible by Mr. Jaffe under section 215, and (2) what                 
          portion of the dividend income from the jointly owned money                 
          market account for 1994 is includable in the respective gross               
          income of Mr. Jaffe and Ms. Jaffe.                                          

                                  FINDINGS OF FACT                                    

          1     Unless otherwise indicated, section references are to the             
          Internal Revenue Code in effect for the year at issue.  All Rule            
          references are to the Tax Court Rules of Practice and Procedure.            




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