- 2 - Carolyn M. Fankhanel, pro se. Charles Baer, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION HALPERN, Judge: By notice of deficiency dated November 21, 1994 (the deficiency notice), respondent determined deficiencies in petitioner's Federal income taxes, and additions to tax, as follows: Additions to Tax Year Deficiencies Sec. 6651(a)(1) Sec. 6654(a) 1983 $7,892 $1,973 $483 1984 2,622 656 165 1985 27,556 6,889 1,579 1986 9,535 2,384 461 1987 1,941 485 104 1988 3,601 900 232 1989 3,892 973 263 1990 198 62 - 1991 1,398 350 80 1992 178 100 - 1993 8,689 2,172 - 1In 1990, $36 was withheld from wages received by petitioner and was submitted to the Internal Revenue Service. Thus, the balance of tax that respondent claims is due from petitioner for that year is $62. The issues for decision are whether (1) respondent’s notice of deficiency is arbitrary, (2) respondent bears the burden of proof with respect to items of unreported income, (3) petitioner may claim personal exemption deductions on account of her two sons, (4) petitioner must report interest payments with respect to child-support arrearages, (5) petitioner must report items of income received in kind, (6) petitioner is entitled to additionalPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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