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Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1992 $14,966 $1,816.25 -0-
1993 17,412 2,399.75 $365.81
1994 17,336 2,569.75 492.70
1995 15,202 1,466.25 1261.76
1The deficiency amounts listed above do not reflect Federal
income tax withheld from petitioner's wages. See, e.g., sec.
301.6215-1, Proced. & Admin. Regs., which provides that "the
entire amount redetermined as the deficiency by the decision of
the Tax Court which has become final shall be assessed," while
only "the unpaid portion of the amount so assessed shall be paid
by the taxpayer upon notice and demand therefor." (Emphasis
added.)
The issues for decision are: (1) Whether amounts paid as
"family support" were alimony and, therefore, deductible by
petitioner. We hold that certain of these amounts were
deductible by petitioner in the amounts stated. (2) Whether
petitioner may deduct various Schedule C, Profit or Loss From
Business, expenses for the taxable years at issue. We hold he
may not. (3) Whether petitioner is entitled to claim additional
exemptions for his spouse and her two daughters for taxable years
1993 through 1995.1 We hold he is not. (4) Whether petitioner
is entitled to head-of-household filing status in 1993 and
married filing joint return status in 1994 and 1995. We hold he
is not. (5) Whether petitioner is liable for additions to tax
1The parties stipulated that petitioner was unmarried during
taxable years 1992 and 1993. For taxable year 1992, the proper
filing status of petitioner is "single". For taxable year 1993,
the proper filing status of petitioner is still at issue.
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Last modified: May 25, 2011