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all Rule references are to the Tax Court Rules of Practice and
Procedure. The decisions to be entered are not reviewable by any
other court, and this opinion should not be cited as authority.
Respondent determined for 1998 a deficiency in Lawrence
Michael Spanier's Federal income tax of $3,468 and an accuracy-
related penalty under section 6662(a) of $694. Respondent also
determined for 1998 a deficiency in Pamela Spanier's Federal
income tax of $2,415 and an accuracy-related penalty under
section 6662(a) and an addition to tax under section 6651(a) of
$483 and $241, respectively.
Lawrence Michael Spanier (Mr. Spanier) and Pamela Spanier
(Ms. Spanier) were formerly married to each other. The issues
for decision are: (1) Which petitioner is entitled to deductions
for dependency exemptions with respect to three children from
their former marriage; (2) whether either petitioner is subject
to the accuracy-related penalty under section 6662(a); and (3)
whether Ms. Spanier is subject to an addition to tax under
section 6651(a)(1) for failure to timely file her 1998 Federal
income tax return.
The stipulated facts and exhibits received into evidence are
incorporated herein by reference. At the time the petitions in
these cases were filed, both petitioners resided in California.
The Court consolidated these cases for purposes of trial,
briefing, and opinion because they involve common facts and
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