- 2 - 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.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