Polly M. Cherry - Page 6

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          stipulation that for the 1994 taxable year petitioner was                   
          entitled to an additional deduction of $1,089 for Eagle office              
          rent.                                                                       
               In the notice of deficiency, respondent determined that                
          petitioner had Schedule C income in the amount of $24,552 for               
          1993, which, at trial, respondent conceded would be adjusted                
          downward so as not to include any disallowed Schedule C expenses.           
          Similarly, respondent determined that petitioner had Schedule C             
          income in 1994 in the amount of $18,530, which, at trial,                   
          respondent conceded would be adjusted downward so as not to                 
          include any disallowed Schedule C expenses.  Additionally,                  
          respondent conceded at trial that petitioner received $2,200 in             
          signatory loans during 1993 and 1994.                                       
               Respondent also determined that Jasmine and Brandy Wilson              
          were not the dependents of petitioner during 1993 and 1994 and,             
          accordingly, denied petitioner's claims to personal exemptions              
          for them.  Additionally, respondent determined that petitioner              
          was not entitled to file her returns for the years in issue using           
          head of household rates.                                                    
               Respondent also determined a deficiency in petitioner's                
          self-employment taxes for 1993 in the amount of $2,997, and                 
          accorded her a corresponding income tax deduction in the amount             
          of $1,498.  For 1994, respondent determined a deficiency in                 
          petitioner's self-employment taxes in the amount of $1,776, and             






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