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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.
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