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Neither the Temporary Orders nor the Permanent Orders
provided for any payment as a substitute for the unallocated
family support payments in the event of Ms. Miller's death.
From January 1 to November 11, 1993, Mr. Lovejoy paid
unallocated family support to Ms. Miller of $32,789 pursuant to
the Temporary Orders. From November 12 to December 31, 1993, Mr.
Lovejoy paid $5,203 in unallocated family support and $200 in
maintenance to Ms. Miller pursuant to the Permanent Orders. On
his 1993 Federal income tax return, Mr. Lovejoy claimed alimony
deductions for his payments of $37,992. On her Federal income
tax return for 1993, Ms. Miller included only the $200 of
maintenance required by the Permanent Orders in her gross income.
From January 1 to February 28, 1994, Mr. Lovejoy made
payments to Ms. Miller of $6,654. Under the terms of the
Permanent Orders, $400 of this amount was maintenance, and $6,254
was unallocated family support. From March 1 to
December 31, 1994, Mr. Lovejoy made payments to Ms. Miller of
$28,070. Of this amount, $19,000 was child support, and $9,070
was maintenance. On his 1994 tax return, Mr. Lovejoy claimed
$18,656 as an alimony deduction. On her 1994 tax return, Ms.
Miller reported alimony income of $9,448.5
5Most of the inconsistency in reporting is explained by
petitioners' inconsistent treatment of the unallocated family
support payments.
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