- 2 - Respondent determined a deficiency in petitioner's 1994 Federal income tax in the amount of $2,644 and additions to tax pursuant to sections 6651 and 6654 in the amounts of $661 and $136.26, respectively. After a concession by respondent,1 the issues for decision are: (1) Whether petitioner is exempt from Federal income taxation because of his status as a member of the Seneca Nation; (2) whether $50 of income is includable in the 1994 tax year if petitioner is not exempt from Federal income taxation; (3) whether petitioner is entitled to claim head-of-household filing status for 1994; (4) whether petitioner is entitled to claim a dependency exemption deduction under section 151 for the 1994 tax year with respect to his son; and (5) whether petitioner is liable for an addition to tax pursuant to section 6654 for failure to pay estimated income tax for the 1994 tax year. Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time that the petition was filed, petitioner resided in Sacramento, California. FINDINGS OF FACT Petitioner is a member of the Seneca Nation. The Seneca Nation is a member of the Iroquois Confederacy of the Six 1 Respondent has conceded that petitioner is not liable for the addition to tax under sec. 6651 for failure to file a Federal income tax return for the 1994 tax year.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011