- 10 -
her. Sec. 1041(a); Balding v. Commissioner, supra. We also hold
that the portion of the monthly payments which was allocated to
interest under the terms of the Separation Agreement is taxable
to petitioner. Gibbs v. Commissioner, supra.
One other matter needs to be addressed. Respondent
determined that petitioner did not qualify for the filing status
of head of household for 1997. The petition failed to address
the issue, and the record is silent on this point. We deem this
issue conceded by petitioner.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011