Polly M. Cherry - Page 2

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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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