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for all years; and (c) is liable for the addition to tax under
section 6651(a)(1) for failure to file timely without reasonable
cause for all years under consideration.
Background
The stipulation of facts and the exhibits received into
evidence are incorporated herein by reference. At the time the
petition in this case was filed, petitioner resided in Colorado
Springs, Colorado.
The parties agree that petitioner did not provide respondent
with Federal income tax returns for 1994, 1995, and 1997 until
after the notice of deficiency was issued. Petitioner claimed on
the returns dependency exemption deductions for a number of
individuals, including his son, his daughter, and for 1994 and
1995, an individual named Stacy Brown. Petitioner’s son and
daughter were both over the age of 19 in 1994. Neither was a
full-time student during the years 1995 through 1997. Both of
his children filed tax returns for the years at issue claiming
personal exemptions for themselves.
In or around 1993, petitioner retired on disability from his
job in computer operations with Federal Express. Petitioner
bought 5 acres of land, originally zoned as agricultural but
subsequently rezoned as rural/residential. During the years
under consideration, petitioner lived on his property in a mobile
home, a 1976 Eaton Park double-wide.
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