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.
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