Andrea Cipriano - Page 6




                                        - 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