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Revenue Code in effect for the year in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency in petitioner’s Federal
income tax for the taxable year 1997 of $1,334. At some point
before trial, petitioner conceded the adjustment in the notice of
deficiency; however, each party made additional claims. The
issues remaining for decision are: (1) Whether petitioner is
entitled to the claimed dependency exemption deductions; (2)
whether petitioner is entitled to head-of-household filing
status; (3) whether petitioner is entitled to the additional
claimed alimony deduction; and (4) whether petitioner is entitled
to the claimed Schedule C, Profit or Loss From Business, expense
deductions.
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the attached exhibits are
incorporated herein by this reference.
Petitioner lived in Clearwater, Florida, at the time he
filed his Tax Court petition.
Background
Petitioner was employed by an architectural firm as a
licensed architect during 1997. Petitioner and his wife,
Virginia Richards (Ms. Richards), had three children, Matthew,
Brigid, and Shannon, who in 1997 were ages 17, 13, and 11,
respectively. Petitioner, Ms. Richards, and their children lived
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