2
Petitioners concede that they failed to report $47 of
taxable interest income received in 1993. Respondent concedes
that petitioners are entitled to two dependency exemption
deductions for their daughters for the years in issue. As a
result of respondent's concession, there is no deficiency in
income tax for 1993. Therefore, we need not decide whether
petitioners are entitled to additional dependency exemption
deductions for 1993, as the issue is moot. However, a deficiency
in self-employment tax remains at issue for 1993. See sec.
1402(a)(7).
After concessions, the issues for decision are whether
petitioners are entitled to two additional dependency exemption
deductions under section 151 with respect to the mother and
sister of Octavio Olvera (petitioner) for 1994, and whether
petitioners are entitled to deductions for automobile and
telephone expenses in excess of amounts allowed by respondent for
either of the years in issue.2
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
Chicago, Illinois, at the time their petition was filed.
Petitioners are from Mexico and have two daughters, Janet
and Illiana. Petitioners moved to the United States to seek
2 The computation of self-employment tax will be resolved by
this issue.
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