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For lack of contrary evidence, we also conclude that the
$6,893, the amount contested by petitioner above the face amount
of check No. 1546, constitutes taxable wage income to petitioner
in 1998. In summary, for 1998, petitioner is to be taxed on
total income relating to his employment with Champion in the
amount of $129,541.3
Dependency Exemptions
In order to be entitled to the two dependency exemptions at
issue in this case, each claimed dependent must qualify under the
statutory definition of “dependent”. Secs. 151(c)(1), 152. The
definition of “dependent” includes a son or daughter of the
taxpayer, over half of whose support was paid by the taxpayer,
and who, at the end of the year, was either under the age of 19
or under the age of 24 and also a student as defined by section
151(c)(4). Secs. 151(c)(1)(B), 152(a)(1).
Petitioner offered no evidence as to his entitlement to the
claimed exemptions. We deny petitioner’s claimed dependency
exemptions.
Additions to Tax
Section 6651(a)(1) imposes an addition to tax for a
taxpayer’s failure to timely file his individual Federal income
3 $27,415 uncontested, plus $95,233 check, plus $6,893
equals $129,541.
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