Randolph John Beale - Page 2




                                                - 2 -                                                  
                       Additions to Tax                                                                
            Year        Deficiency        Sec. 6651(a)(1)               Sec. 6654                      
            1992        $14,966           $1,816.25               -0-                                  
            1993        17,412            2,399.75                $365.81                              
            1994        17,336            2,569.75                492.70                               
            1995        15,202            1,466.25                       1261.76                       
                  1The deficiency amounts listed above do not reflect Federal                          
            income tax withheld from petitioner's wages.  See, e.g., sec.                              
            301.6215-1, Proced. & Admin. Regs., which provides that "the                               
            entire amount redetermined as the deficiency by the decision of                            
            the Tax Court which has become final shall be assessed," while                             
            only "the unpaid portion of the amount so assessed shall be paid                           
            by the taxpayer upon notice and demand therefor."  (Emphasis                               
            added.)                                                                                    
                  The issues for decision are:  (1) Whether amounts paid as                            
            "family support" were alimony and, therefore, deductible by                                
            petitioner.  We hold that certain of these amounts were                                    
            deductible by petitioner in the amounts stated.  (2) Whether                               
            petitioner may deduct various Schedule C, Profit or Loss From                              
            Business, expenses for the taxable years at issue.  We hold he                             
            may not.  (3) Whether petitioner is entitled to claim additional                           
            exemptions for his spouse and her two daughters for taxable years                          
            1993 through 1995.1  We hold he is not.  (4) Whether petitioner                            
            is entitled to head-of-household filing status in 1993 and                                 
            married filing joint return status in 1994 and 1995. We hold he                            
            is not.  (5) Whether petitioner is liable for additions to tax                             




                  1The parties stipulated that petitioner was unmarried during                         
            taxable years 1992 and 1993.  For taxable year 1992, the proper                            
            filing status of petitioner is "single".  For taxable year 1993,                           
            the proper filing status of petitioner is still at issue.                                  




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011