Robert L. Stahl - Page 2




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                                 MEMORANDUM OPINION                                   

               HALPERN, Judge:  By notice of deficiency dated February 18,            
          1998 (the notice), respondent determined deficiencies in                    
          petitioner’s 1994 and 1995 Federal income taxes of $2,569 and               
          $12,390, respectively.                                                      
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years at issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
                The issues for decision concern (1) petitioner’s deductions           
          for (A) alimony paid and (B) an additional personal exemption and           
          (2) petitioner’s omission from gross income of an amount received           
          from Vanguard Fiduciary Trust Co.                                           
               Some facts have been stipulated and are so found.  The                 
          stipulation of facts, with accompanying exhibits, is incorporated           
          herein by this reference.  We need find few facts in addition to            
          those stipulated and shall not, therefore, separately set forth             
          our findings of fact.  We shall make additional findings of fact            
          as we proceed.  Petitioner bears the burden of proof.  See Rule             
          142(a).                                                                     
                                     Background                                       
               At the time the petition was filed, petitioner resided in              
          Australia.                                                                  






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