2
All statutory 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, except as
otherwise noted.
On brief, respondent has conceded the additions to tax that
were determined against petitioner under section 6651 for both
1990 and 1991; respondent has also conceded the addition to tax
under section 6654 for the year 1990. Petitioner and respondent
have agreed that petitioner's income and deductions for the years
1990 and 1991 shall be determined as shown in the returns (Forms
1040) which were filed by petitioner with the Internal Revenue
Service (IRS) for the years in issue, and which are in evidence
herein, save for the right of petitioner to claim dependency
exemptions with respect to her three minor children in each year.
Accordingly, there remains only for the Court to determine: (1)
Whether petitioner is entitled to claim dependency exemptions
under sections 151 and 152 with regard to her three minor
children for 1990 and 1991; and (2) whether petitioner is liable
for the addition to tax for the year 1991 under section 6654.
Petitioner Rebecca A. Peck was a resident of Missouri at the
time the petition herein was filed. At some time prior to 1984,
petitioner and William S. Peck were married. Three children were
born of this marriage: two in 1984 (twins) and one in 1982.
Petitioner and William S. Peck were divorced in the courts
of Missouri in November 1987. By decree of the State court in
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