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Respondent determined deficiencies and penalties under
section 6662(a) for negligence in petitioner’s 1996 and 1997
Federal income taxes as follows:
Year Deficiency Penalty
1996 $3,336 $667.20
1997 2,524 504.80
The issues are whether petitioner is entitled to: (1)
Dependency exemption deductions for his mother (Dorothy Garrett)
and his brother (Neil Garrett) for the years in issue; (2) head
of household filing status for the years in issue; (3) Schedule C
loss deductions of $15,254 and $10,363 for 1996 and 1997,
respectively; and (4) whether petitioner is liable for the
penalties under section 6662(a) for the years in issue.
Petitioner resided in Roanoke, Virginia, at the time he filed the
petition in this case.
Petitioner is a school teacher. During 1996 petitioner
taught in the Alexandria, Virginia, school system. During 1997
petitioner taught in the Alexandria and Roanoke, Virginia, school
systems, but it is unclear when he went to Roanoke. Petitioner
rented his residence in Alexandria. According to petitioner,
when in Alexandria, he would go to Roanoke every weekend and stay
at a house his mother owned and occupied and that his brother
also occupied. Presumably when he was employed in Roanoke, he
stayed in the same house. For 1996 and 1997, petitioner reported
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