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find that, except to the extent of $23,800, petitioner has not
established that respondent's determination in the notice of
unreported income for 1986, as reduced by her concession on
brief, is wrong.11
Dependency Exemption
Although petitioner contends on brief that his son, Charles
McClaine, lived with him during 1986 and that petitioner is
therefore entitled to claim him as a dependent for that year, the
record is devoid of evidence supporting that contention.
On the record before us, we find that petitioner has failed
to establish that he is entitled for 1986 to an exemption for a
dependent child under section 151(a) and (c).
Additions to Tax--Section 6653(a)(1)(A) and (B)
Respondent determined in the notice that petitioner is
liable for 1986 for the additions to tax under section
6653(a)(1)(A) and (B) with respect to the underpayment for that
year that is attributable only to the following determinations:
(1) Disallowance of a personal exemption in the amount of $1,080,
11 Respondent determined in the notice pursuant to the cash
expenditures method that petitioner had $122,461 of unreported
income for 1986. On brief, respondent takes the position that
petitioner's unreported income for 1986 calculated pursuant to
that method is $117,208. We construe respondent's position on
brief as a concession by respondent that the amount of unreported
income for 1986 determined in the notice should be reduced by
$5,253. In making the computation required under Rule 155, the
parties shall, inter alia, use $117,208 as the starting point for
computing the amounts of the deficiency in, and additions to,
petitioner's income tax for 1986 that result from this Opinion
and other concessions of the parties.
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