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Paul Eugene Groff, for petitioner.
J. Scott Hargis and Joyce Marr, for respondent.
MEMORANDUM OPINION
LARO, Judge: This case is before the Court fully
stipulated. See Rule 122. Violet A. Reynolds petitioned the
Court to redetermine respondent's determination of a $5,805
deficiency in her 1994 Federal income tax and an $1,161
accuracy-related penalty under section 6662(a). The principal
issue we decide is whether payments received by petitioner under
a settlement agreement are includable in her gross income. We
hold they are not.1 Unless otherwise stated, section references
are to the Internal Revenue Code in effect for the subject year.
Rule references are to the Tax Court Rules of Practice and
Procedure.
Background2
Petitioner and Gregg P. Kent (Mr. Kent) were involved in a
close personal relationship from 1967 until 1991, and they
cohabited as an unmarried couple during the last 24 years of the
relationship. Mr. Kent told petitioner early in the relationship
1 The only other issue in dispute is the applicability of
the accuracy-related penalty. Our holding on the principal issue
renders this other issue moot.
2 The parties have stipulated all facts. The stipulation of
facts and the exhibits submitted therewith are incorporated
herein by this reference. When the petition was filed,
petitioner resided in Seal Beach, California.
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