Charles L. Wynn, Jr. - Page 12

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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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