Gabriel M. Daya, et al. - Page 2




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          Gabriel Mahmoud Daya (Gabriel), docket Nos. 9061-98 and 1976-99:            
                                        Penalty                                       
               Year      Deficiency     Sec. 6662(a)                                  
               1995      $1,620         $324                                          
               1996      1,515          303                                           
          Morhaf Michael Daya (Morhaf), docket No. 9062-98:                           
                                        Penalty                                       
               Year      Deficiency     Sec. 6662(a)                                  
               1995      $1,312         $262                                          
                                                                                     
          Unless otherwise indicated, section references are to the                   
          Internal Revenue Code in effect for the years in issue, and all             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.  The cases have been consolidated for purposes of                
          trial, briefing, and opinion.                                               
               The issues for decision are:                                           
               1.  Whether Gabriel is entitled to dependency exemption                
          deductions for his father in taxable years 1995 and 1996.  We               
          hold that he is not.                                                        
               2.  Whether Gabriel is entitled to head of household filing            
          status in taxable years 1995 and 1996.  We hold that he is not.             
               3.  Whether Morhaf is entitled to head of household filing             
          status in taxable year 1995.  We hold that he is not.                       
               4.  Whether Gabriel is entitled to claim mortgage interest             
          deductions in taxable years 1995 and 1996 in excess of that                 
          allowed by respondent.  We hold that he is not.                             
               5.  Whether Morhaf is entitled to a mortgage interest                  
          deduction in taxable year 1995.  We hold that he is not.                    





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