Chris E. Columbus - Page 10

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                  Q    And in regard to your oldest daughter, she                     
                       did reach 19 before the end of 1992. Correct                   
                  A    Correct.                                                       
                  Q    And you do not know whether she was a full-                    
                       time student in 1992--                                         
                  A    Correct.                                                       
                  Q    -- or in 1993 --                                               
                  A    Correct.                                                       
                  Q    -- or in 1994.                                                 
                  A    Correct.                                                       

             Because petitioner did not prove that his oldest daughter                
             had gross income less than the exemption amount or was a                 
             student during the years in issue, he has failed to meet                 
             his burden of proving that he is eligible to claim a                     
             personal exemption for her.  Accordingly, we find that                   
             petitioner is entitled to only five personal exemptions                  
             for each of the years in issue.                                          
                  Third, respondent determined in the notice of                       
             deficiency that the entire amount that petitioner received               
             from the sale of his employer's stock in each of the years               
             in issue is taxable as gain realized from the sale.  The                 
             notice of deficiency describes this adjustment as follows:               








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