Robert E. Corrigan - Page 35

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          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                  








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