Linda Sanders - Page 11

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          Department stated that petitioner was not required to file a                
          return in 1992, and petitioner argues that the Treasury                     
          Department's authority supersedes respondent's determination in             
          the deficiency notice.                                                      
               Petitioner's arguments are without merit and lack factual              
          and legal foundation.  In that regard, we are not obligated to              
          exhaustively review and rebut petitioner's misguided contentions.           
          Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984) ("We             
          perceive no need to refute these arguments with somber reasoning            
          and copious citation of precedent; to do so might suggest that              
          these arguments have some colorable merit.")  Accord Casper v.              
          Commissioner, 805 F.2d 902 (10th Cir. 1986), affg. T.C. Memo.               
          1985-154.                                                                   
          Standard Deduction                                                          
               Respondent determined that petitioner was not entitled to a            
          standard deduction for 1992 because she was married filing                  
          separate returns.  Respondent allowed petitioner a $3,700                   
          standard deduction for 1993.  Section 63(c) permits a standard              
          deduction, in addition to deductions for personal exemptions,               
          from adjusted gross income to determine taxable income.  A                  
          married individual filing a separate return where either spouse             
          itemizes deductions is not eligible for a standard deduction.               
          Sec. 63(c)(6)(A).  Petitioner did not present any evidence with             







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