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MEMORANDUM FINDINGS OF FACT AND OPINION
WHERRY, Judge: This case is before the Court on a petition
for redetermination of a $6,582 deficiency in Federal income tax
that respondent determined for petitioner’s 2003 taxable year.
Respondent also determined an accuracy-related penalty pursuant
to section 6662(a) and (b)(1) in the amount of $1,316.40.1 The
issues for decision are:
(1) Whether $26,400 paid to petitioner in 2003 by her ex-
husband was includable in petitioner’s 2003 taxable income as
alimony under section 71(a) and (b); and
(2) whether petitioner is liable for an accuracy-related
penalty under section 6662(a) and (b)(1) in the amount of
$1,316.40.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts and the accompanying exhibits are hereby incorporated by
reference into our findings. At the time she filed her petition,
petitioner resided in Chattanooga, Tennessee.
On July 1, 1998, petitioner and her husband, Dr. Thornton D.
Perkins (Dr. Perkins), entered into a marital dissolution
agreement (MDA), which was approved by the Chancery Court of
1 All section references are to the Internal Revenue Code of
1986, as amended and in effect for the taxable year at issue.
The Rule references are to the Tax Court Rules of Practice and
Procedure.
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Last modified: March 27, 2008