- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011