Irene E. Jones, a.k.a. Irene E. Perry-Jones a.k.a. Irene E. Perry - Page 2

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          the Tax Court Rules of Practice and Procedure.  The Court agrees            
          with and adopts the opinion of the Special Trial Judge, which is            
          set forth below.                                                            
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               WOLFE, Special Trial Judge:  Respondent determined                     
          deficiencies in petitioner's Federal income taxes for the taxable           
          years 1993 and 1994, additions to tax for failure to file timely            
          Federal income tax returns pursuant to section 6651(a)(1), and              
          accuracy-related penalties for negligence as follows:                       
                                   Additions to Tax        Penalty                    
               Year      Deficiency     Sec. 6651(a)(1)     Sec. 6662(a)              
               1993      $6,333         $1,165              $1,267                    
               1994      7,550          1,338               1,510                     
               After concessions by both parties,1 the issues for decision            
          with respect to petitioner's taxes for 1993 and 1994 are:  (1)              
          Whether petitioner is entitled to claim her daughter, Melanie               
          Roberts, also known as Melanie Stroman, and Nicole Roberts,                 
          Melanie Roberts' daughter and petitioner's granddaughter, as                
          dependents; (2) whether petitioner is entitled to head of                   
          household filing status; (3) whether petitioner overstated her              
          itemized deductions by $28,565 and $19,061 on Schedule A of her             


          1                                                                           
               The parties stipulated that petitioner is not entitled to a            
          dependency exemption for Latoya Roberts for the taxable years               
          1993 and 1994.  During the trial, respondent conceded that                  
          petitioner was entitled to deductions for union dues for the                
          taxable years 1993 and 1994 in the amounts of $971.76 and $1,163,           
          respectively.                                                               




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