Legal Opinion

Perry v. Commissioner

United States Tax Court

Decided March 16, 1989No. Docket Nos. 6507-83, 14905-84, 15225-84Published

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

Carolyn Pratt Perry, Petitioner v. Commissioner of Internal Revenue, Respondent

Perry v. Commissioner

Docket Nos. 6507-83, 14905-84, 15225-84

United States Tax Court

92 T.C. 470; 1989 U.S. Tax Ct. LEXIS 33; 92 T.C. No. 28;

March 16, 1989; As amended March 22, 1989 March 16, 1989, Filed

Decisions will be entered under Rule 155.

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…

2Cases cited16 opinions

  1. Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
  2. Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
  3. Reiff v. CommissionerUnited States Tax Court · 1981
  4. Estate of Reynolds v. CommissionerUnited States Tax Court · 1970
  5. Marcus v. BurnettSupreme Court of Louisiana · 1973

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