- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011