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trial that he believed his fellowship award was excludable from
income and that he was not required to file returns for those
years. Petitioner claimed in his testimony that he based his
belief on the advice of an unnamed IRS employee whom petitioner
contacted shortly after he received a notice in his student
mailbox at Drexel that there had been a change in the law
regarding the taxability of scholarships and fellowships. Even
assuming arguendo that petitioner did contact an IRS employee
while he was attending Drexel, any advice he received at that
time would not exculpate him from his failure to file a tax
return for 1990 after his transfer to CUNY and subsequent request
for a 1-year extension of his MARC fellowship had been granted.
Accordingly, we sustain respondent's determination that
petitioner is liable for the addition to tax under section
6651(a) for 1990.
Respondent also determined an addition to tax against
petitioner under section 6654(a) for failure to make timely
7(...continued)
notices of deficiency, respondent determined that petitioner's
filing status was "single".
We will not, as a general rule, consider an issue raised for
the first time at trial since it has not been properly pleaded.
See Estate of Mandels v. Commissioner, 64 T.C. 61, 73 (1975).
Additionally, we note that the documents attached to petitioner's
posttrial brief were not introduced at trial and therefore are
not part of the record in this case. Rule 143(b). Consequently,
even if petitioner's filing status were an issue before us, we
would nevertheless find that petitioner has not established that
he is eligible to file as "head of household" during the years in
issue.
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