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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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