T.C. Memo. 2004-284
UNITED STATES TAX COURT
MUMTAZ A. ALI, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3064-03. Filed December 27, 2004.
Dennis G. Harkavy, for petitioner.
Elaine T. Fuller, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined a deficiency in
petitioner’s 2000 Federal income tax of $34,262.
Petitioner and his former spouse, Shagufta Lisa Ali (Ali),
had two children and owned a community interest in the Spearmint
Rhino Clubs (SRC), a corporation. Petitioner and Ali separated
in 1999. SRC paid Ali $24,000 per month from June to December
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