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Rules 180, 181, and 183.1 The Court agrees with and adopts the
Opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
ARMEN, Special Trial Judge: Respondent determined a
deficiency in petitioner's Federal income tax for the taxable
year 1992 in the amount of $2,096 and an addition to tax under
section 6651(a)(1) in the amount of $519. In contrast,
petitioner claims an overpayment in the amount of $352,100.
After concessions by petitioner,2 the issues for decision
are as follows:
(1) Whether respondent may, in determining the deficiency in
income tax against petitioner, disregard the community property
laws of the State of Arizona;
(2) Whether, for purposes of determining the applicable tax
rates and standard deduction, petitioner's filing status is that
of a married person filing jointly, a married person filing
separately, or a head-of-household;
(3) whether petitioner is entitled to dependency exemption
deductions for her three children;
1 Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect for 1992, the taxable year
in issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
2 Petitioner concedes that she worked for Sandia Oil Co.
and Show Low Gemstones, Inc. in 1992 and received wages during
that year from those companies in the amounts of $5,735 and
$13,518, respectively.
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