Robert L. Stahl - Page 8




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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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