Ahsan Mohiuddin - Page 2

                                        Accuracy-related penalty                      
               Year       Deficiency        Sec. 6662(a)1                             
               1990           $658           $124                                     
               1991         17,246           3,449                                    
               1992          1,517           303                                      

               Some of the issues raised by the pleadings have been                   
          disposed of by agreement of the parties, leaving for decision:              
          (1) Whether petitioner is entitled to use the filing status of              
          "head of household" for the taxable years 1990 and 1991, and                
          whether petitioner is entitled to use the filing status of                  
          "single" for the taxable year 1992; (2) whether petitioner is               
          entitled to a dependency exemption for his mother for each of the           
          taxable years 1990 and 1991; (3) whether petitioner is entitled             
          to deduct on Schedule A the amounts of $5,539, $37,247.73, and              
          $7,823, or any part thereof, for the taxable years 1990, 1991,              
          and 1992, respectively; (4) whether petitioner is entitled to               
          Schedule C business expense deductions in the amounts of $23,505            
          and $7,250 for the taxable years 1991 and 1992, respectively; and           
          (5) whether petitioner is liable for an accuracy-related penalty            
          pursuant to section 6662(a) for each of the taxable years at                
          issue.2                                                                     

          1  All section references are to the Internal Revenue Code                  
          in effect for the years in issue, and all Rule references are to            
          the Tax Court Rules of Practice and Procedure, unless otherwise             
          indicated.                                                                  
          2  In her Answer to Amended Petition, respondent alleged                    
          that petitioner was liable for an addition to tax pursuant to               
          sec. 6651(a) for failure to timely file petitioner's Federal                
          income tax return for the taxable year 1990.  In her trial                  
                                                             (continued...)           




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