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After concessions by the parties, the issues for decision
are:
(1) Whether payments made to petitioner, pursuant to a long-
term disability income settlement, by Connecticut General Life
Insurance Co. (Connecticut General) are taxable gross income to
petitioner in 2002;
(2) whether Citibank interest income of $972, attributable
to the Quadrino & Schwartz, P.C. (Quadrino & Schwartz), escrow
account, and $15 of interest income from a U.S. savings bond are
taxable to petitioner in 2002;
(3) whether petitioner is entitled to certain credits,
exemptions, or deductions in 2002;
(4) whether petitioner is liable for the additions to tax
under section 6651(a)(1) and (2); and
(5) whether petitioner’s proper filing status for 2002 is
married filing separately.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
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