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Respondent argues that petitioner was required to file
Federal income tax returns for the 5 taxable years at issue and
that petitioner is liable for deficiencies for each of those
years. Respondent asserts that petitioner was required to report
the short-term capital gain from his sale of Intel Corporation
stock in 2003. Respondent next claims that petitioner is not
entitled to dependency exemptions for his wife for the 2000,
2002, and 2003 taxable years because petitioner has provided no
evidence that his wife was dependent on him. With respect to
education credits or a deduction for tuition and fees,
respondent’s position is that petitioner has failed to
substantiate that any qualified tuition and related expenses were
paid by him. Regarding the claimed moving expense deduction,
respondent concedes that petitioner and his wife moved from
Oregon to New Mexico but argues that it is not clear when the
move occurred and that only petitioner’s self-serving testimony
supports petitioner’s assertion that the move was work related.
Turning to additions to tax, respondent contends that
petitioner is liable for additions to tax under section
6651(a)(1) for the 5 taxable years at issue because there is no
dispute that petitioner failed to file Federal income tax returns
for those years and petitioner has failed to demonstrate
reasonable cause for such action. Respondent also contends that
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Last modified: March 27, 2008