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6662(a)1 on, petitioners’ respective Federal income tax for 2002:
Petitioners Deficiency Accuracy-Related Penalty
Dwight S. Platt and $3,531 $706
Antonina K. Platt
Herbert Bangs and 2,175 435
Christine Bangs
We must decide whether certain payments that petitioner
Herbert Bangs (Mr. Bangs) made during 2002 to petitioner Antonina
Platt (Ms. Platt) are deductible or excludable from Mr. Bangs’
income for his taxable year 2002 and includible in Ms. Platt’s
income for her taxable year 2002.2 We hold that they are not.
FINDINGS OF FACT
All of the facts in these cases, which the parties submitted
under Rule 122, have been stipulated by the parties and are so
found except as stated below.
Petitioners in the case at docket No. 4467-06, Ms. Platt and
Dwight Platt (Mr. Platt), resided in Stevenson, Maryland, at the
time they filed the petition in that case. Petitioners in the
case at docket No. 7221-06, Mr. Bangs and Christine Bangs (Ms.
1Unless otherwise indicated, all section references are to
the Internal Revenue Code (Code) in effect for the year at issue.
All Rule references are to the Tax Court Rules of Practice and
Procedure.
2Respondent made certain additional determinations in the
respective notices of deficiency that respondent issued to
petitioners in these cases, the resolution of which flows auto-
matically from our resolution of the determinations in those
respective notices that we address herein. See also infra note
33.
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