T.C. Memo. 2004-98
UNITED STATES TAX COURT
JAY MUKHERJEE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13523-02. Filed April 7, 2004.
D. Robert Autry, Jr., for petitioner.
Nancy E. Hooten, for respondent.
MEMORANDUM OPINION
WELLS, Chief Judge: Respondent determined a deficiency in
the amount of $17,400 in petitioner’s Federal income tax for
2000. The sole issue for decision is whether petitioner is
entitled to deduct under section 215 as alimony a payment that he
made to his former wife pursuant to the judgment of a State court
entered on a jury’s verdict in their divorce proceedings awarding
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