John R. Kirkpatrick v. Commissioner

T.C. Memo. 2018-20

UNITED STATES TAX COURT JOHN R. KIRKPATRICK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11181-16. Filed February 22, 2018. P was ordered in a divorce proceeding interim order to transfer $100,000 directly and nontaxably into an IRA titled in W’s name and further to pay W $40,000 for attorney’s fees and suit money. P directed distributions from his IRAs into a checking account from which he wrote checks to W and to third parties. P reported the $140,000 of distributions (among others, the taxability of which he has conceded) as nontaxable on his…