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During 1995, and in accordance with the supplemental final
judgment, petitioner paid Ms. Hodson $3,000 in cash.
By check dated December 21, 1995 (the check), Vanguard
Fiduciary Trust Co. (Vanguard) paid $23,192.18 to the order of
Meagan Elizabeth Stahl. The check states: “E-Systems, Inc.”,
“Disbursement Account”, and “Plan Number 091184". For 1995,
Vanguard issued a Form 1099R, “Distributions From Pensions,
Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance
Contracts, etc.”, to petitioner,3 showing a gross distribution
from account number 091184 of $23,192.18 (the Vanguard
distribution).
On petitioner’s 1994 U.S. Individual Income Tax Return, Form
1040 (1994 Form 1040), he deducted $20,000 for alimony paid. On
his 1995 U.S. Individual Income Tax Return, Form 1040 (1995
Form 1040), he deducted $15,500 for alimony paid. He also showed
Meagan as his daughter and dependent and, on account thereof,
deducted $2,500 as a personal exemption deduction. He failed to
include as an item of gross income the Vanguard distribution.
In the notice, respondent adjusted petitioner’s income for
both years by disallowing the claimed deductions for alimony
paid. For 1995, respondent further adjusted petitioner’s income
3 On the Form 1099R, the recipient’s name is shown as “R.L.
Stahl”. The recipient’s “identification number” is identical to
petitioner’s Social Security number. We, therefore, find that
Vanguard intended to name petitioner as recipient of the
Form 1099R.
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