- 2 - Respondent determined for 2002 a deficiency in petitioner’s Federal income tax of $5,291 and a section 6662(a) accuracy- related penalty of $922. Petitioner did not contest in the petition or at trial whether she had unreported taxable interest in 2002. Therefore, petitioner is deemed to have conceded the issue. Rule 34(b)(4); see Funk v. Commissioner, 123 T.C. 213, 215 (2004). The issues for decision are whether petitioner: (1) Had unreported Schedule C gross receipts for 2002, (2) is entitled to Schedule C deductions for taxes and licenses expenses, (3) is entitled to claim a dependency exemption for her daughter, MA,1 and (4) is liable for a section 6662(a) accuracy-related penalty. Background The stipulation of facts and the exhibits received into evidence are incorporated herein by reference. At the time the petition in this case was filed, petitioner resided in Stockton, California. Petitioner is a native speaker of Spanish. One of her daughters, Gisell Pompa, acted as her interpreter at trial. During 2002, petitioner was self-employed, engaging in retail sales in a flea market. Petitioner was also employed by “M&R” in 2002. In 2002, petitioner made a number of trips to a casino called Jackson Rancheria where she gambled almost exclusively on 1The Court will refer to the minor child by her initials.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011