Rebecca A. Peck - Page 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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