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issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
Respondent determined deficiencies in petitioner’s Federal
income tax of $40,017 for 1994, $3,446 for 1995, and $12,959 for
1997. Respondent also determined additions to tax under:
Section 6651(a)(1) of $9,397.50 for 1994, $254.75 for 1995, and
$1,448.55 for 1997; section 6651(a)(2) of $869.13 for 1997; and
section 6654 of $175.09 for 1994 and $305.68 for 1997.
A substantial number of issues have been resolved and are
listed in the stipulation of settled issues filed on October 25,
2006. In addition to their mutual agreements, the parties have
made separate concessions: (1) Petitioner concedes that his
basis in 30.8760 shares of certain Federal Express Corp. stock
sold in 1994 is equal to one-half of the $2,154.34 gross
proceeds; (2) petitioner concedes all deductions for dependency
exemptions except those for his son, his daughter, and one Stacy
Brown; (3) respondent concedes the additions to tax under section
6654 for 1994 and 1997; and (4) respondent concedes the addition
to tax under section 6651(a)(2) for 1997.
The issues remaining for decision are whether petitioner:
(a) Is entitled to deductions for dependency exemptions for his
son and daughter for 1994, 1995, and 1997, and for one Stacy
Brown for 1994 and 1995; (b) is entitled to losses from various
activities reported on Schedules C, Profit or Loss From Business,
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