Estate of Goldman v. Commissioner
United States Tax Court
On Nov. 12, 1985, H and W executed a Property Settlement Agreement (the agreement) in connection with their divorce; the agreement was approved by the divorce court. Par. 2 of the agreement provides for a division of marital property. Par. 2.2.9 of the agreement provides that "In furtherance of the equitable division of property" H shall pay W $ 20,000 a month for 240 months. The monthly payments terminate at W's death.
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On Nov. 12, 1985, H and W executed a Property Settlement Agreement (the agreement) in connection with their divorce; the agreement was approved by the divorce court. Par. 2 of the agreement provides for a division of marital property. Par. 2.2.9 of the agreement provides that "In furtherance of the equitable division of property" H shall pay W $ 20,000 a month for 240 months. The monthly payments terminate at W's death. Par. 6.5 of the agreement provides that all transfers of property are to be subject to the provisions of sec. 1041, I.R.C., and shall be reported on H and W's income tax…
1Opinion of the Court
Jacobs, Judge:
In the notice of deficiency respondent determined the following income tax deficiencies and accuracy-related penalties:
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After resolving a protective adjustment for the year 1992 (involving the deduction of expenses of an S corporation which passed through to Monte H. Goldman), the parties agree that the amounts of deficiencies and accuracy-related penalties now at issue are:
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The issues remaining for decision are: (1) Whether payments of $240,000 Monte H. Goldman made to Sally Parker during each year in issue were properly deductible as alimony, and (2)…
2Cases cited5 opinions
- Metra Chem Corp. v. CommissionerUnited States Tax Court · 1987
- Richard E. Hoover v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1996
- Arthur C. Hawkins v. Commissioner of Internal Revenue, Glenda R. Hawkins v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1996
- Edward J. Richardson v. Commissioner of Internal Revenue, Irene E. Richardson v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1997
- Hawkins v. CommissionerUnited States Tax Court · 1994
3Cited by37 opinions
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- Baker v. CommissionerUnited States Tax Court · 2000
- Simpson v. Comm'rUnited States Tax Court · 2003
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