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Federal income tax returns for the taxable years 1993 and 1994,
respectively; (4) whether petitioner is liable for additions to
tax under section 6651(a)(1) for 1993 and 1994 for failure to
file returns timely; and (5) whether petitioner is liable for the
accuracy-related penalties under section 6662(a) for 1993 and
1994.
The evidence in this case consists of a stipulation of facts
with attached exhibits (incorporated herein by reference) and
oral testimony and exhibits admitted during the trial. When the
petition was filed, petitioner resided in Blue Bell,
Pennsylvania.2
Background
On July 29, 1994, petitioner filed her 1993 Federal income
tax return on which she identified her filing status as head of
household and claimed dependency exemptions for the following
three individuals: Latoya Roberts (hereinafter Latoya), Nicole
Roberts (hereinafter Nicole), and Melanie Roberts (hereinafter
Melanie). On July 17, 1995, petitioner filed her 1994 Federal
income tax return on which she again identified her filing status
as head of household and claimed dependency exemptions for the
same three individuals. Melanie, also known as Melanie Stroman,
2
In her petition, petitioner also requested a redetermination
of deficiencies relating to the 1991 taxable year. The petition
with respect to the 1991 year subsequently was dismissed for lack
of jurisdiction by an order of this Court dated July 17, 1997.
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