Mumtaz A. Ali - Page 1

                                 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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