- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011