- 2 -
of $1,952 under section 6651(a)(1)1 for failing to timely file
his 1990 tax return.
Before trial, petitioner conceded that his daughter, Wendy
Walker, did not qualify as his dependent under sections 151 and
152 as claimed on his Federal income tax return. In his opening
brief, petitioner conceded that he was liable for the addition to
tax under section 6651(a)(1). The remaining issues for decision
are: (1) Whether petitioner is entitled to claim certain trade
or business deductions; (2) whether payments of $2,400 made to
his former wife qualify as alimony; and (3) whether petitioner is
entitled to file as a "head of household" for 1990.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of fact and attached exhibits are incorporated
herein by this reference. Petitioner resided in Landover,
Maryland, at the time the petition was filed in this case.
During the year in issue, petitioner worked for the District
of Columbia Department of Administrative Services. The office
where petitioner worked was located in the Gallery Place area of
Washington, D.C. Petitioner earned approximately $52,728 at his
position with the D.C. government. In 1990, petitioner lived
1All section references are to the Internal Revenue Code in
effect for the year in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011