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Respondent determined deficiencies in petitioner’s Federal
income taxes and accuracy-related penalties under section 6662(a)
as follows:
Penalties
Year Deficiency Sec. 6662(a)
1999 $5,280 $739.40
2000 5,147 944.60
After concessions, the issues for decision for 1999 and 2000
are: (1) Whether petitioner is entitled to claimed dependency
exemption deductions and related child tax credits; (2) whether
petitioner is entitled to deductions claimed on Schedule C,
Profit or Loss From Business, with respect to her secretarial
services business; and (3) whether petitioner is liable for
accuracy-related penalties under section 6662.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. When she filed her
petition, petitioner resided in Richton Park, Illinois.
On her Federal income tax returns for 1999 and 2000,
petitioner reported wages of $38,444 in 1999 and $42,005 in 2000
from her job as an administrative assistant at a law firm in
Chicago, Illinois.
In her testimony petitioner disavowed most of the deductions
claimed on her tax returns for 1999 and 2000. Petitioner’s
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