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6662(a).1 Respondent later raised a new issue and asserted an
increased deficiency of $6,520 and an accuracy-related penalty of
$1,304.
The issues for decision are: (1) Whether petitioners are
entitled to 10 dependency exemption deductions for their
children; (2) if petitioners are entitled to the deductions,
whether they are liable for the alternative minimum tax; and (3)
whether petitioners were negligent, disregarded rules or
regulations, or substantially understated their income tax.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by reference. Petitioners resided in Glen
Mills, Pennsylvania, at the time their petition was filed.
Petitioners claimed dependency exemption deductions for
their 10 children on their joint 1997 Form 1040, U.S. Individual
Income Tax Return. Petitioners wrote “NA” in the section
provided for listing the Social Security numbers (SSN’s) of
claimed dependents. Petitioners’ children are all U.S. citizens
under the age of 18 and do not have SSN’s.
1 Unless otherwise indicated, 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.
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Last modified: May 25, 2011