Polly M. Cherry - Page 18

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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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