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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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