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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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Last modified: March 27, 2008