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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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