Benigno Antonio Gasparutti - Page 2

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          tax under section 6651(a)(1) in the amount of $228, and an                  
          accuracy-related penalty under section 6662(a) in the amount of             
               The issues for decision are:  (1) Whether petitioner is                
          entitled to claim $21,130 in itemized deductions on Schedule A;             
          (2) whether petitioner is entitled to claim a dependency                    
          exemption deduction for his son; (3) whether petitioner is                  
          entitled to claim head-of-household filing status; (4) whether              
          petitioner is liable for the addition to tax under section                  
          6651(a)(1); and (5) whether petitioner is liable for the                    
          accuracy-related penalty under section 6662(a).                             
               No stipulation of facts has been filed in this case.2  At              
          the time he filed his petition, petitioner resided in Aliso                 
          Viejo, California.                                                          
          Schedule A                                                                  
               During 1994, petitioner was employed as a general machinist            
          at Mag Instruments, Inc. (Mag) in Ontario, California.                      
          Petitioner worked for Mag from September 1992 until September               
          1995 when he was terminated.  Before working for Mag, petitioner            
          lived in Aliso Viejo, California.  Petitioner took the job with             

          2  At the conclusion of trial, the Court set a schedule for                 
          the parties to file seriatim briefs.  Petitioner did not file a             
          brief.  We could declare petitioner in default and dismiss his              
          case.  Rule 123; Stringer v. Commissioner, 84 T.C. 693 (1985),              
          affd. without published opinion 789 F.2d 917 (4th Cir. 1986).               
          However, we decline to do so, and we shall decide the case on the           
          merits.  See Calcutt v. Commissioner, 84 T.C. 716 (1985).                   

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