Fred J. Pettid - Page 2




                                         - 2 -                                        
                                 Year      Deficiency                                 
                                 1993      $19,578                                    
                                 1994      18,964                                     
                                 1995      19,578                                     
                  After concessions, the sole issue for decision is                   
             whether monthly payments that petitioner made to Ms. Inga                
             Wagner during the years in issue are properly treated as                 
             alimony and deductible under section 215(a) of the Internal              
             Revenue Code, as petitioner contends, or as nondeductible                
             payments in settlement of a claim for damages, as                        
             determined by respondent.  Unless stated otherwise, all                  
             section references in this opinion are to the Internal                   
             Revenue Code in effect for the years in issue.  Ms. Wagner               
             was formerly known as Inga Wagner Bartling, and in various               
             documents constituting the record of this case, Ms. Wagner               
             is sometimes referred to as Ms. Bartling.                                

                                  FINDINGS OF FACT                                    
                  This case was submitted fully stipulated pursuant to                
             Rule 122 of the Tax Court Rules of Practice and Procedure.               
             All Rule references in this opinion are to the Tax Court                 
             Rules of Practice and Procedure.  The stipulation of facts,              
             supplement to stipulation of facts, and the attached                     
             exhibits are incorporated herein by this reference.                      
             Petitioner resided in Omaha, Nebraska, at the time he filed              
             his petition in this case.                                               





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