Charles Mandeville - Page 2




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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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