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181, and 182.1 Respondent determined deficiencies in
petitioner's Federal income taxes and accuracy-related penalties
under section 6662(a) as follows:
Accuracy-Related Penalty
Year Deficiency Sec. 6662(a)
1994 $5,204.00 $1,040.80
1995 4,909.37 981.87
After concessions,2 the issues for decision are: (1)
Whether petitioner underreported gross income on her return for
the taxable year 1994; (2) whether petitioner is entitled to cost
of goods sold claimed on Schedules C of her returns for the
taxable years 1994 and 1995; (3) whether petitioner is entitled
to dependency exemptions for the taxable years 1994 and 1995; (4)
whether petitioner is entitled to head-of-household filing status
for the taxable years 1994 and 1995; and (5) whether petitioner
is liable for the accuracy-related penalty under section 6662(a)
for the taxable years 1994 and 1995.
FINDINGS OF FACT
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the attached exhibits are
1 All section references are to the Internal Revenue Code
in effect for the years in issue, unless otherwise indicated.
All Rule references are to the Tax Court Rules of Practice and
Procedure.
2 Petitioner concedes that she is not entitled to car and
truck expenses claimed on Schedule C of her 1994 tax return in
the amount of $3,132.
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