Jeanne E. Amarasinghe - Page 6




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          they reported $179,368 as taxable income from pensions and                  
          annuities, and reported a deduction for alimony paid of $116,350.           
          In 2004, they filed a Form 1040X, Amended U.S. Individual Income            
          Tax Return, for 2002.  On the Form 1040X, they removed the                  
          $179,368 distribution from pensions and annuities income and the            
          $116,350 deduction for alimony paid.                                        
               Ms. Amarasinghe also filed a 2002 Form 1040 in 2003.  On her           
          return, Ms. Amarasinghe reported income of $75,318 as alimony               
          received and did not report any income from pensions and                    
          annuities.                                                                  
               On May 26, 2006, respondent issued a notice of deficiency to           
          Dr. Amarasinghe and his spouse.  Respondent effectively                     
          disallowed the Form 1040X amended return and determined that the            
          deduction for alimony paid was limited to $75,318.  After                   
          adjusting their deductions and credits, respondent determined a             
          deficiency in income tax of $12,085 for 2002.                               
               On May 26, 2006, respondent issued a notice of deficiency to           
          Ms. Amarasinghe.  Respondent determined that she received pension           
          income in the amount of $179,368 and that she received no alimony           
          income in 2002.  After adjusting her deductions and exemptions,             
          respondent determined a deficiency in income tax of $36,548.                
               Petitioners timely filed separate petitions with this Court.           










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