Princess Stephan Obriot - Page 9




                                        - 8 -                                         

          petitioner, in view of her low income, is faced with financial              
          hardship in paying the taxes and interest assessed on the                   
          deficiencies for 1995 and 1996, she should consider submitting to           
          respondent an offer in compromise based on inability to pay and             
          requesting the abatement of interest on the deficiencies.                   
               Respondent also contends that petitioner was not eligible to           
          claim head of household filing status in 1996.  Section 2(b), in            
          relevant part, defines a head of household as an unmarried                  
          taxpayer who maintains as her home a household which constitutes            
          for more than one-half of the taxable year the principal place of           
          abode of her daughter.  Sec. 2(b)(1)(A)(i).  The taxpayer is                
          considered as maintaining a household only if over half of the              
          cost of maintaining the household is furnished by the taxpayer.             
          Sec. 2(b)(1).  "The expenses of maintaining a household include             
          property taxes, mortgage interest, rent, utility charges, upkeep            
          and repairs, property insurance, and food consumed on the                   
          premises."  Sec. 1.2-2(d), Income Tax Regs.  Based on the                   
          evidence, we find that petitioner paid more than one-half of the            
          above expenses.  Accordingly, we hold that petitioner is entitled           














Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011