Leona Payton - Page 3

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               Respondent determined deficiencies in petitioner’s Federal             
          income taxes and accuracy-related penalties in the following                
          amounts for the following taxable years:                                    
               Year      Deficiency          Sec. 6662(a)                             
               1995      $1,830              $357.00                                  
               1996      2,051               410.20                                   
               1997      1,875          375.00                                        
               After concessions by petitioner,1 the issues for decision              
          are: (1) Whether petitioner is entitled to dependency exemption             
          deductions for several individuals for the years 1995, 1996, and            
          1997; (2) whether petitioner is entitled to head of household               
          status; (3) whether petitioner is entitled to an earned income              
          credit for 1996; and (4) whether petitioner is liable for                   
          accuracy-related penalties for 1995, 1996, and 1997.                        
               Some of the facts in this case have been stipulated and are            
          so found.  The stipulation of facts and the exhibits received               
          into evidence at trial are incorporated herein by this reference.           
          At the time the petition was filed, petitioner lived in St.                 
          Louis, Missouri.                                                            
               Petitioner lived in a 2-bedroom apartment with a roommate              
          from 1995 through 1997.  During these years, petitioner assisted,           

               1    Petitioner concedes that she received $309 wage income            
          from Incarnate Word Hospital and $42 interest income during 1995            
          which she failed to report on her 1995 Federal income tax return.           
          Petitioner further concedes that she did not provide more than              
          half of the total support for her mother, Mattie Barnes, during             
          1995, and stepfather, John Jones, during 1995 and 1996.                     

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