- 3 -
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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