- 35 -
34459 (Aug. 31, 1984). Cf. Miller v. Commissioner, 114 T.C. 184,
188-189 (2000), affd. on other grounds sub nom. Lovejoy v.
Commissioner, 293 F.3d 1208 (10th Cir. 2002).
Accordingly, petitioner is entitled to claim dependency
exemptions for Amy in 1987 through 1991 and for Robert in all
years including 1988, 1989, and 1990 (the years denied by
respondent).
With respect to Mrs. Corrigan, petitioner is not entitled to
claim a personal or dependency exemption because they were
divorced, and she did not reside in his household. Secs. 151(b),
152(a)(9).
X. Negligence Additions to Tax and Accuracy-Related
Penalties
For 1987 and 1988, respondent determined that petitioner was
liable for an addition to tax for negligence under section
6653(a)(1) equal to 5 percent of the underpayment. For 1987,
respondent also determined that petitioner was liable under
section 6653(a)(1)(B) for an amount equal to 50 percent of the
interest payable on the portion of the underpayment attributable
to negligence. For 1989 through 1991, respondent determined that
petitioner was liable for a 20-percent accuracy-related penalty
under section 6662(a) due to negligence or intentional disregard
of the rules or regulations. The standards and principles
Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 NextLast modified: May 25, 2011