T.C. Memo. 2003-275 UNITED STATES TAX COURT PATRICIA P. KEAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent ROBERT W. KEAN, III, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket Nos. 8966-00, 9144-00. Filed September 22, 2003. R determined deficiencies for H’s 1995 and 1996 taxable years. R’s determinations were based upon R’s inconsistent position that payments made by H to W, pursuant to pendente lite unallocated support orders, were includable in the gross income of W as alimony received, and not deductible by H as alimony paid. H filed a petition for redetermination. This Court held that the payments were alimony for Federal income tax purposes and were deductible by H, under sec. 215, I.R.C. H seeks recovery of litigation costs pursuant to sec. 7430, I.R.C., in the amount of $54,012.63. *This opinion supplements our previously filed opinion in Kean v. Commissioner, T.C. Memo. 2003-163.Page: 1 2 3 4 5 6 7 Next
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