Allyson Christina Briggs - Page 3

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               Respondent determined a deficiency in Federal individual               
          income tax against petitioner for 1999 in the amount of $523.               
               The issue for decision is whether petitioner’s net loss from           
          her trade or business of providing cleaning and lawn mowing                 
          services must be subtracted from her Form W-2 income in                     
          determining her “earned income” under section 63(c)(5)(B),                  
          relating to limitation on basic standard deduction in the case of           
          certain dependents.                                                         
               The instant case was submitted fully stipulated; the                   
          stipulations, stipulated exhibits, and other exhibits received at           
          the hearing are incorporated herein by this reference.                      
               When the petition in the instant case was filed, petitioner            
          resided in Washington, Missouri; she also resided there during              
          1999, the year in issue.                                                    
               On her timely filed 1999 income tax return--                           
                    (1) petitioner claimed a tax filing status of                     
                    (2) petitioner did not claim a personal exemption                 
               deduction, instead that deduction was claimed on her                   
               parents’ tax return (see sec. 151(d)(2)); and                          
                    (3) petitioner claimed a standard deduction of                    

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