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Respondent determined a deficiency and additions to tax in
petitioner’s Federal income tax as follows:
Additions to Tax1
Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654(a)
1996 $6,918 $1,557 $1,384 $368
1 The following figures are rounded to the nearest dollar.
After concessions,1 the issues for decision are: (1) Whether
petitioner may deduct, as alimony under section 215, military
retirement pension payments made to his former wife; (2) if the
payments are not deductible under section 215, whether petitioner
may nevertheless exclude from his income any portion of his
military retirement pension paid to his former wife; (3) whether
petitioner is liable for the addition to tax under section
6651(a)(1) for failure to file a Federal income tax return; and
(4) whether petitioner is liable for the addition to tax under
section 6654(a) for an underpayment of estimated tax.
Background
Some of the facts are stipulated, and they are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time of filing his
petition, petitioner resided in Palmer Lake, Colorado.
1 Petitioner concedes that he received $39,900 of military
retirement pension income and $18 of interest income and that he
is not entitled to deductions claimed on Schedule E, Supplemental
Income and Loss, and Schedule K-1, Partner’s Share of Income,
Credits, Deductions, etc. Respondent concedes the addition to
tax under sec. 6651(a)(2) for failure to pay Federal income tax.
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