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After concessions,1 the issues for decision are: (1)
Whether petitioner is entitled to claim his son, Bradley C. Njoku
(Bradley), as a dependent. We hold he is not. (2) Whether
petitioner has established entitlement to deductions claimed for
medical expenses claimed on his return. We hold he has, to the
extent set out below. (3) Whether petitioner is entitled to
claim a credit for child care expenses. We hold he may, to the
extent set out below. (4) Whether petitioner is entitled to
deduct expenses he claimed were incurred in searching for a job.
We hold he is not. (5) Whether petitioner is liable for the
section 6662(a) accuracy-related penalty for the underpayment of
income tax attributable to negligence or disregard of rules or
regulations.2 We hold he is.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
1Initially, respondent disallowed the dependency exemptions
claimed by petitioner for his son and daughter for the year at
issue. Respondent also determined that petitioner had unreported
income of $24,583 and that petitioner was not entitled to head-
of-household filing status. At trial, respondent conceded the
unreported income issue, and that petitioner was entitled to head
of household filing status and one dependency exemption for his
daughter, Michelle.
2Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure. All dollar amounts are rounded to the
nearest dollar, unless otherwise indicated.
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Last modified: May 25, 2011