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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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