Carolyn M. Fankhanel - Page 1

                                 T.C. Memo. 1998-403                                  

                               UNITED STATES TAX COURT                                

                        CAROLYN M. FANKHANEL, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 2835-95.              Filed November 12, 1998.              

                    P failed to file returns for 11 years.  P claims                  
               that R’s notice of deficiency constituted a “naked                     
               assessment”, that she is entitled to additional                        
               dependency exemptions for some years, that she received                
               no interest income on child-support arrearages, that                   
               she had additional rental property connected expenses,                 
               and that she is not liable for additions to tax.                       
                    Held:  R’s determination of deficiencies is not                   
               arbitrary and, thus, is not a naked assessment.  Held,                 
               further, sufficient evidence supports R’s determination                
               of unreported income.  Held, further, P received                       
               interest on child-support arrearages.  Held, further,                  
               P failed to prove her entitlement to additional                        
               dependency exemptions.  Held, further, P failed to                     
               prove additional rental-property-connected expenses.                   
               Held, further, P is liable under secs. 6651(a)(1) and                  
               6654(a), I.R.C., additions to tax.  Held, further, on                  
               Court’s own motion, a penalty in the amount of $5,000                  
               is imposed under sec. 6673(a)(1), I.R.C.                               

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