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wage income of $29,594 and $20,024, respectively. During 1997
petitioner also received unemployment compensation of $3,390.
Petitioner’s mother received Social Security benefits of
$5,598 and $5,7602 for 1996 and 1997, respectively. She also
received retirement benefits of $1,754 for each year.
Petitioner’s brother also received Social Security benefits, but
the amounts do not appear in the record.
Petitioner claimed his mother and brother as dependents and
also claimed head of household filing status based on their
dependency exemptions. Respondent disallowed both dependency
exemption deductions and determined that petitioner could not
claim head of household filing status.
Petitioner was also engaged in an activity that he described
as follows:
Well, I do self esteem workshops, I do consulting on
problems, social issues, I do behavior modification if
people are having problems with the kids.
****** *
Well, see, I sell products, too, fragrances, oils,
incense, and things like that.
Petitioner commenced this activity in 1986, and, according to
petitioner, the activity has never shown a profit. Petitioner
did not maintain a separate checking account for this activity
2 Figure rounded to the nearest dollar.
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Last modified: May 25, 2011