James E. Harrell - Page 3




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               Respondent determined a deficiency of $2,770 and a section             
          6651(a)(1) addition to tax of $598.25 in petitioner's Federal               
          income tax for the year 1994.  This Court must decide: (1)                  
          Whether petitioner qualifies for head of household filing status;           
          (2) whether petitioner substantiated the amounts claimed as                 
          itemized deductions for medical expenses, taxes paid, interest              
          expenses, charitable contributions, unreimbursed employee                   
          business expenses, and other expenses; and (3) whether petitioner           
          is liable for an addition to tax for failing to timely file his             
          1994 tax return.  If petitioner's itemized deductions are less              
          than the standard deduction, then petitioner will be entitled to            
          the standard deduction under section 63(b), as respondent                   
          determined.                                                                 
               Petitioner resided in Aurora, Colorado, at the time he filed           
          his petition.                                                               
               In 1993, petitioner and his wife were legally separated.               
          During 1994, petitioner's four children lived with their mother.            
          They spent 2-3 nights per week at petitioner's house.  Petitioner           
          provided financial support for his children.  Under the 1996                
          decree of dissolution, petitioner was entitled to claim                     
          dependency exemption deductions for two of his four children.  On           
          his 1994 return, which was filed on July 3, 1997, petitioner                
          claimed head of household filing status.  Respondent determined             
          that petitioner's filing status should be single.                           





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