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6330(d) of respondent’s decision to proceed with collection of
petitioner’s Federal income tax liabilities for 1993 and 1994.
Some of the facts were stipulated. Those facts, with the
annexed exhibits, are so found and are made part hereof.
Petitioner’s legal residence was Reserve, Louisiana, at the time
the petition was filed.
Petitioner filed Federal income tax returns for the years
1993 and 1994 reporting head-of-household filing status and
claiming deductions for a personal exemption for herself and five
dependency exemptions for her sister and four “foster” children.
The latter were children of petitioner’s friend, Joann Louise
Kleibert.
Upon examination of the returns, respondent disallowed the
five claimed dependency exemption deductions and determined that
petitioner’s filing status was married filing separately instead
of head-of-household. Respondent also determined that petitioner
was liable for income taxes on unreported community property
income. A notice of deficiency was issued to petitioner for the
years 1993 and 1994 in which the following determinations were
made:
Year Deficiency Sec. 6662(a) Penalty
1993 $1,447 $289
1994 1,297 259
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