- 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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