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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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