- 2 -
is not reviewable by any other court, and this opinion should not
be cited as authority.
In separate notices of deficiency, respondent determined the
following deficiencies in Federal income taxes and penalties
against petitioner and her husband, Moses A. Blankson, for the
years indicated:2
Year Deficiency Sec. 6662(a) Penalty
1993 $10,971 $2,191
1994 5,681 1,136
1995 6,066 1,204
1996 9,259 1,851
After concessions,3 the issues for decision are: (1)
Whether assessment or collection of the deficiency and penalty
2 With regard to one of the notices of deficiency, for
the 1993 and 1994 tax years, petitioner and her husband (Mr.
Blankson) filed a petition with this Court in docket No. 16417-
97. At the time the petition was filed, petitioner had a pending
bankruptcy proceeding. On motion by respondent, petitioner was
dismissed from the case for lack of jurisdiction. Mr. Blankson
remained in the case and later conceded the deficiencies and
penalties for the years 1993 and 1994. Thereafter, respondent
issued a notice of deficiency to petitioner and Mr. Blankson for
the 1995 and 1996 tax years. About that time, petitioner’s
bankruptcy proceeding was concluded, and petitioner timely filed
a petition with respect to both notices of deficiency for the
years 1993, 1994, 1995, and 1996. Mr. Blankson did not petition
the Court with respect to the 1995 and 1996 notice of deficiency.
3 At trial, petitioner conceded a dependency exemption
deduction for her son, Samuel, for 1993. Respondent conceded his
determination that petitioner failed to report a $73 taxable
distribution for 1993 and $2,753 in wage and salary income for
1995.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011