Tweeddale v. Commissioner
United States Tax Court
P claimed to be a minister and that all of his income was tax-exempt on his 1983 Federal income tax return. R determined deficiencies and additions to tax under secs. 6653(a)(1), 6653(a)(2), and 6661, I.R.C. 1954, against P in 1983 based on P's claim to be tax-exempt. P conceded that he was not tax-exempt and now claims entitlement to a dependency exemption, partnership loss, and head of household filing status.
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P claimed to be a minister and that all of his income was tax-exempt on his 1983 Federal income tax return. R determined deficiencies and additions to tax under secs. 6653(a)(1), 6653(a)(2), and 6661, I.R.C. 1954, against P in 1983 based on P's claim to be tax-exempt. P conceded that he was not tax-exempt and now claims entitlement to a dependency exemption, partnership loss, and head of household filing status. Held, P failed to prove his entitlement to the dependency exemption, partnership loss, and head of household filing status. Held, further, additions to tax under secs. 6653(a)(1) and…
1Opinion of the Court
Parr, Judge:
Respondent determined a deficiency of $28,483.50 against petitioner in 1983, and additions to tax as follows:
Sec. 6653(a)(1) 1 Sec. 6653(a)(2) Sec. 6661
$1,424.18 $1,736.30 $2,848.35
At trial, respondent was granted leave to amend his answer to assert an increase in the section 6661 addition totax to 25 percent from 10 percent in accordance with the Omnibus Reconciliation Act of 1986, Pub. L. 99-509, 100 Stat. 1874, 1951.
Petitioner now claims that he is entitled to a dependency exemption for his son, a partnership loss in the amount of $39.58, and head of household filing status. We…
2Cases cited17 opinions
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- Bixby v. CommissionerUnited States Tax Court · 1972
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Pallottini v. CommissionerUnited States Tax Court · 1988
- Woods v. CommissionerUnited States Tax Court · 1988
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