Perry v. Commissioner
United States Tax Court
Petitioner's ex-husband failed to make certain court-ordered payments in 1980, 1981, and 1982. Petitioner's expenditures for support of their minor children during each of these years exceeded that year's unpaid amount. Petitioner paid the airfare to send their children to stay with the children's grandparents; and she paid a babysitter's share of social security taxes as part of the babysitter's compensation.
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Petitioner's ex-husband failed to make certain court-ordered payments in 1980, 1981, and 1982. Petitioner's expenditures for support of their minor children during each of these years exceeded that year's unpaid amount. Petitioner paid the airfare to send their children to stay with the children's grandparents; and she paid a babysitter's share of social security taxes as part of the babysitter's compensation. Held: 1. Petitioner is not entitled to a bad debt deduction for any of the years because she has no basis in any of the debts. Swenson v. Commissioner, 43 T.C. 897 (1965), followed. 2.…
1Opinion of the Court
Chabot, Judge:
Respondent determined deficiencies in Federal individual income tax and additions to tax under section 6651(a)(1)1 (failure to file timely tax returns) against petitioner as follows:
Additions to tax
Docket No. Year Deficiency sec. 6651(a)(1)
6507-83 1980 $433
14905-84 1981 1,349
15225-84 1982 2,477 2$362.25
By amendment to answer, respondent asserts an increased deficiency for 1980 in the amount of $539.58, for a total deficiency in the amount of $972.58. This is based on disallowance of a deduction of $3,000 and is disputed. At trial, respondent also asserted that petitioner had a…
2Cases cited15 opinions
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Reiff v. CommissionerUnited States Tax Court · 1981
- Estate of Reynolds v. CommissionerUnited States Tax Court · 1970
- Marcus v. BurnettSupreme Court of Louisiana · 1973
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3Cited by20 opinions
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