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effect for the year in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
Respondent determined a $23,860 deficiency in petitioner’s
2002 Federal income tax. Respondent also determined an addition
to tax under section 6651(a)(1) and an accuracy-related penalty
under section 6662 in the amounts of $2,386 and $4,772,
respectively.
The issues before the Court are: (1) Whether $122,200 is
includable in petitioner’s income as alimony; (2) whether
petitioner failed to report $2,317 in interest income; (3)
whether petitioner is liable for the alternative minimum tax;1
(4) whether petitioner is liable for the addition to tax under
section 6651(a)(1) for failure to timely file; and (5) whether
petitioner is liable for the accuracy-related penalty.
Background
Some of the facts are stipulated and are so found. At the
time the petition in this case was filed, petitioner resided in
Orland Park, Illinois.
Petitioner and Mohammed M. Nahhas (Mr. Nahhas) were married
on July 31, 1980. Three children were born in the marriage, NN,
1 Respondent has determined that petitioner is liable for
alternative minimum tax for her 2002 taxable year. This issue is
computational in nature and will be addressed in a Rule 155
computation.
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Last modified: May 25, 2011