- 18 - (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 eachPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011