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(A) maintains as his home a household which
constitutes for more than one-half of such taxable year
the principal place of abode, as a member of such
household,
of--
* * * * * * *
(ii) any other person who is a dependent of
the taxpayer, if the taxpayer is entitled to a
deduction for the taxable year for such person
under section 151 * * *
Because we have found that petitioner has failed to prove
that Jasmine and Brandy Wilson were the dependents of petitioner
during the years in issue we find that petitioner is not entitled
to file as a head of household for those years.
Petitioner's Liability for Self-Employment Tax
Section 1401 provides that a tax shall be imposed on the
self-employment income of every individual. Petitioner has the
burden of proving that she is not liable for self-employment
taxes. Rule 142(a). Petitioner has failed to offer any evidence
or make any arguments that she is not liable for self-employment
taxes. Consequently, we hold that petitioner is liable for self-
employment taxes.
Petitioner's Failure To File Timely Her 1993 Return
Respondent determined that petitioner was liable for the
addition to tax provided by section 6651(a) for 1993. Where a
taxpayer fails to file an income tax return on the date
prescribed for filing, section 6651(a)(1) imposes an addition to
tax equal to 5 percent of the amount required to be shown on the
return, with an additional 5 percent to be added for each
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