Florence C. Blankson - Page 4




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          for 1993 is barred by the statute of limitations under section              
          6501(a); (2) whether petitioner is entitled to various Schedule             
          A, Itemized Deductions, and Schedule C, Profit or Loss From                 
          Business, deductions in excess of amounts allowed by respondent             
          for 1993 through 1996; (3) whether petitioner is entitled to                
          charitable contribution deductions under section 170 in excess of           
          amounts allowed by respondent for 1993, 1994, and 1995; (4)                 
          whether petitioner is entitled to a trade or business loss                  
          deduction under section 165 for 1996; (5) whether petitioner is             
          entitled to a dependency exemption deduction for her sister under           
          section 151 for 1993 and 1994; (6) whether petitioner is entitled           
          to a child care credit under section 21 for 1995; and (7) whether           
          petitioner is liable for the accuracy-related penalty under                 
          section 6662(a) for 1993 through 1996, inclusive.4                          
               Some of the facts were stipulated.  Those facts, with the              
          annexed exhibits, are so found and are made part hereof.                    




               4    In a supplemental posttrial brief, petitioner argued              
          that her 1994 tax liability should have been included in her                
          bankruptcy proceeding.  The Court construes that as an argument             
          that this Court has no jurisdiction over her 1994 tax liability             
          and that such jurisdiction should be in the bankruptcy court.               
          The Court rejects such argument.  Although this Court lacks                 
          jurisdiction as to whether a tax liability has been discharged in           
          bankruptcy, this Court nevertheless has jurisdiction to determine           
          the amount of the deficiency.  Neilson v. Commissioner, 94 T.C.             
          1, 8-9 (1990); Graham v. Commissioner, 75 T.C. 389, 399-400                 
          (1980).                                                                     





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