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1996 and 1997. Subject to respondent’s concessions and
adjustments, we hold that she did.
(4) Whether petitioner is entitled to a dependency exemption
for Carl Collins for 1998. We hold that she is not.
(5) Whether petitioner is liable for accuracy-related
penalties under section 6662(a) for 1996 and 1997. We hold that
she is to the extent provided herein.
Adjustments relating to petitioner’s itemized deductions for
the taxable years at issue, self-employment taxes for 1996 and
1997, the earned income credit for 1996 and 1997, and the child
tax credit for 1998 are purely perfunctory matters, the
resolution of which is dependent on our disposition of the issues
above.
Background
Some of the facts have been stipulated, and they are so
found. Petitioner resided in Ocala, Florida, at the time that
her petition was filed with the Court.
During the taxable years at issue, petitioner was employed
on a full-time basis as a paralegal. Petitioner received wages
from employment in the amounts of $43,454, $46,277, and $42,443
during 1996, 1997, and 1998, respectively.3
Petitioner has two children. In addition to her own
children, petitioner helped raise Carl Collins, the child of a
3 All amounts are rounded to the nearest dollar.
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