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1994 Federal income tax. Petitioner, however, failed to attend
this meeting.
On October 6, 1998, respondent mailed to petitioner a notice
of deficiency regarding petitioner’s 1994 and 1996 Federal income
taxes. In the notice of deficiency sent to petitioner for 1994
and 1996, respondent determined that petitioner failed to report
as taxable income on her respective Federal income tax returns
the above $10,6642 and $4,950 payments that petitioner received
from her ex-spouse in 1994 and 1996 that were denominated as
interest.3
In the petition filed with this Court, petitioner raised as
a new issue a claimed ordinary deduction in the amount of $79,688
for expenses relating to attorney, accountant, and appraiser fees
allegedly incurred in connection with her divorce, the division
of marital property, and the installment payments. Petitioner
does not indicate whether the $79,688 should be deducted in 1994
or in 1996 or how the expenses should be allocated between 1994
and 1996.
2 The record does not explain the $30 variance in amounts
denominated as interest by the Superior Court of New Jersey
Chancery Division of Monmouth County and by respondent in the
notice of deficiency.
3 The record does not reflect whether respondent mailed to
petitioner a statutory notice of deficiency regarding
petitioner’s 1995 Federal income tax.
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Last modified: May 25, 2011