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Unless otherwise indicated all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
The issues we must decide in the instant case are whether
petitioner is: (1) Entitled to business expenses in the amount
of $19,412 for 1993 and business expenses in the amount of
$18,519 for 1994; (2) liable for tax on unreported income for the
years in issue; (3) entitled to personal exemptions for Jasmine
S. Wilson and Brandy N. Wilson (Jasmine and Brandy Wilson) as
dependents for the years in issue; (4) entitled to file her
returns for the years in issue using head of household rates; (5)
liable for self-employment tax pursuant to section 1401 for each
of the years in issue; (6) liable for the addition to tax under
section 6651(a) for failure to timely file her 1993 return; and
(7) liable for the accuracy-related penalty provided by section
6662(a) for each of the years in issue.
FINDINGS OF FACT
Some of the facts and certain exhibits have been stipulated
for trial pursuant to Rule 91. The parties' stipulations of fact
are incorporated by reference and are found as facts in the
instant case.
At the time she filed her petition, petitioner resided in
Albany, Georgia.
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