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Respondent determined deficiencies in petitioners’ Federal
income taxes, an addition to tax, and penalties as follows:
Sec. Sec.
Petitioner(s) Year Deficiency 6651(a)(1) 6662(a)
Tyrone Sharp 1999 $5,344 --- $1,068.80
Alvera Sharp 1999 1,178 --- 235.60
Tyrone & Alvera Sharp2000 4,012 $703 802.40
After concessions, the following issues remain for
consideration: (1) Whether Social Security disability benefits
received in 1999 by Tyrone Sharp (petitioner) are includable in
his income for that year; (2) whether petitioner is entitled to
an alimony deduction for 1999 for certain payments made during
that year to, or on behalf of, his former spouse; and (3) whether
petitioner is liable for a section 6662(a) accuracy-related
penalty for 1999.
Some of the facts have been stipulated and are so found. At
the time the petition was filed, petitioners resided in
Inverness, Florida.
Petitioner and Margaret Sharp (petitioner’s former spouse)
married in 1994 and divorced in 1999. They entered into a Joint
Stipulation and Settlement Agreement (settlement agreement) with
the Circuit Court of the Fifth Judicial Circuit In and For Citrus
County, Florida, on September 20, 1999. Relevant for our
purposes, the settlement agreement contains the following
provisions:
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