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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