- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011