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He lived with his father during 1983 and during the majority of
1984. Petitioner provided no support for Syme during the time he
lived with his father.
Zachary lived with petitioner until he moved out of her
house in January 1988. In August 1988, Zachary began college in
Colorado. In 1988, petitioner's father, Warren Fankhanel,
provided $4,000 so that Zachary could attend college. In 1989,
petitioner's father provided an additional $13,000 towards
Zachary’s college. In May 1990, Zachary graduated from college.
Zachary was a full-time student during 1988, 1989, and 1990. He
earned wage income of $8,234 in 1990.
OPINION
I. Introduction
Petitioner has assigned error to respondent’s determination
of deficiencies in, and additions to, petitioner’s Federal income
taxes for the years in question. Petitioner states that the
entire deficiency for each year is in controversy. In support of
her assignments of error, petitioner avers that (1) the amounts
stated as gross and taxable income in the deficiency notice are
incorrect, (2) petitioner is entitled to the normal business
deductions for the years in issue, (3) petitioner is entitled to
the normal personal deductions associated with the years in
issue, and (4) because no deficiencies exist, no additions to tax
apply. Petitioner also raises as a defense the claim that this
Court lacks jurisdiction to hear this case because respondent’s
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Last modified: May 25, 2011