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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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