Dwight S. & Antonina K. Platt - Page 5




                                        - 5 -                                         
                  Date of Payment                 Amount of Payment                   
                     01/14/2002                        $728.91                        
                     02/13/2002                        728.91                         
                     03/13/2002                        728.91                         
                     04/15/2002                        728.91                         
                     05/13/2002                        728.91                         
                     06/13/2002                        728.91                         
                     07/15/2002                        728.91                         
                     08/15/2002                        740.30                         
                     09/16/2002                        740.30                         
                     10/15/2002                        740.30                         
                     11/15/2002                        740.30                         
                     12/16/2002                        740.30                         
               Mr. Bangs and Ms. Bangs timely filed Form 1040, U.S. Indi-             
          vidual Income Tax Return (Form 1040), for their taxable year 2002           
          (Mr. Bangs’ return).6  In that return, Mr. Bangs claimed a deduc-           
          tion of $8,8837 for alimony.  Mr. Bangs did not issue to Ms.                
          Platt and did not file with the Internal Revenue Service any Form           
          1099 for a nominee distribution with respect to those payments.             
               On January 18, 2006, respondent issued to Mr. Bangs a notice           
          of deficiency with respect to his taxable year 2002 (notice for             
          Mr. Bangs’ taxable year 2002).  In that notice, respondent                  
          disallowed the alimony deduction that Mr. Bangs claimed in Mr.              
          Bangs’ return.  In the notice for Mr. Bangs’ taxable year 2002,             


               6For convenience, we shall generally refer hereinafter only            
          to Mr. Bangs, and not to Ms. Bangs.                                         
               7See supra note 5.  The record does not disclose why Mr.               
          Bangs deducted as alimony $79.13 in excess of the $8,803.87 that            
          he paid to Ms. Platt during that year pursuant to that divorce              
          decree provision.                                                           





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next 

Last modified: March 27, 2008