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under section 6651(a)(2) of $445.49, and an addition to tax under
section 6654(a) of $132.49. After concessions,2 there are three
issues remaining for decision:
(1) Whether petitioner is entitled to a dependency
exemption deduction under section 151(c) for his daughter. We
hold that he is not;
(2) whether petitioner is entitled to a deduction for
itemized expenses in an amount greater than the standard
deduction. We hold that he is not;
(3) whether petitioner is liable for the addition to tax
under section 6651(a)(1) for failing to file a return. We hold
that he is.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulated facts and the accompanying exhibits are
incorporated herein by this reference.
Petitioner resided in Mebane, North Carolina, at the time he
filed his petition.
2 The parties agree that petitioner received $44,883.20 of
gross income in 2003. Respondent concedes that petitioner is not
liable for the addition to tax under sec. 6651(a)(2) or sec.
6654. Respondent also concedes that petitioner is entitled to
deduct a portion of his medical and dental expenses and taxes
paid, although those concessions would not allow petitioner
itemized deductions in an amount greater than the standard
deduction.
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