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MEMORANDUM FINDINGS OF FACT AND OPINION
WHERRY, Judge: This case is before the Court on a petition
for judicial review of five separate notices of deficiency in
which respondent determined the following deficiencies and
additions to tax with respect to petitioner’s Federal income
taxes for the taxable years and in the amounts as follows:1
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1998 $874 $156.50
2000 4,715 491
2001 12,991 3,247.75 $519.15
2002 9,313 202.75
2003 11,679 655.25
The issues for decision are:
(1) Whether petitioner was required to file Federal income
tax returns and is liable for income tax deficiencies in
petitioner’s 1998, 2000, 2001, 2002, and 2003 taxable years;
(2)whether petitioner was required to report $3,839.23 in
net short-term capital gain on the sale of stock in taxable year
2003;
(3) whether petitioner can claim a dependency exemption for
his wife for the 2000, 2002, and 2003 taxable years;
(4) whether petitioner is entitled to an education credit
under section 25A for the 2001 and 2002 taxable years or a
1 The actual amount of the deficiencies remaining unpaid for
all the taxable years at issue except 2001 is significantly less
because a portion of the tax due had been withheld.
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Last modified: March 27, 2008