Malcolm Elwood McClain - Page 3




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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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