Ajuba Gaylord - Page 2

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          section 6662(a)1 in the amounts of $715 for 1999 and $504 for               
          2000.                                                                       
               After concessions,2 the issues to be decided are:                      
               (1) Whether petitioner is entitled to deductions for various           
          expenses claimed on Schedule C, Profit or Loss From Business, for           
          the taxable years 1999 and 2000.  We find that petitioner is                
          entitled to some of the deductions.                                         
               (2) Whether petitioner is eligible for head-of-household               
          filing status in 2000 and a dependency exemption deduction for              
          her brother for that year.  We hold she is not.                             
               (3) Whether petitioner is liable for accuracy-related                  
          penalties pursuant to section 6662(a) for the years at issue.  We           
          hold she is.                                                                
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts, the second stipulation of facts, and              
          the attached exhibits are incorporated herein by this reference.            
          At the time the petition was filed, petitioner resided in New               
          York, New York.                                                             



               1 Unless otherwise indicated, all section references are to            
          the Internal Revenue Code in effect for the years at issue.  All            
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
               2 The concessions of petitioner and respondent, as well as             
          the amounts which remain in dispute, are detailed in table 2,               
          infra p. 5.                                                                 




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