Loretta Manukainiu - Page 2

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            related penalty under section 6662(a) in the amount of $567.  At                            
            trial, respondent conceded the accuracy-related penalty under                               
            section 6662(a).  The remaining issues for decision are: (1)                                
            Whether petitioner is entitled to any dependency exemption                                  
            deductions; (2) whether petitioner is entitled to claim head of                             
            household filing status; and (3) whether petitioner is entitled                             
            to an earned income credit.                                                                 
                  Some of the facts have been stipulated and are so found.                              
            Petitioner resided in San Mateo, California, at the time the                                
            petition was filed.                                                                         
                  During 1993, petitioner was married to Tali Manukainiu and                            
            had four children: Antonio, Naufahu, Soane, and Ofa.  Petitioner                            
            and her husband were not legally separated in 1993.  On her 1993                            
            Federal income tax return, petitioner claimed her son Antonio,                              
            her 34-year-old brother Fuiva Liu, and her parents as dependents.                           
            Petitioner's husband claimed their three other children as                                  
            dependents on his return.  During 1993, petitioner's brother and                            
            father were United States residents, and each had Social Security                           
            numbers.  Neither filed a return for the 1993 tax year.                                     
                  The determinations of the Commissioner in a notice of                                 
            deficiency are presumed correct, and the burden is on the                                   
            taxpayer to show that the determinations are incorrect.  Rule                               
            142(a); Welch v. Helvering, 290 U.S. 111 (1933).                                            

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