Carolyn M. Fankhanel - Page 2

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               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 additional           




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