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