- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008