Astrida Terauds, (1997)

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Astrida Terauds, (1997)

T.C. Memo. 1997-64

UNITED STATES TAX COURT ASTRIDA TERAUDS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10433-95. Filed February 4, 1997.

Astrida Terauds, pro se.

Gary W. Bornholdt, for respondent.

MEMORANDUM OPINION DAWSON, Judge: This case was assigned to Special Trial Judge D. Irvin Couvillion pursuant to section 7443A(b)(4)1 and Rules 180, 181, and 183. The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE COUVILLION, Special Trial Judge: Respondent determined Federal income tax deficiencies of $10,703 and $7,954 and additions to tax under section 6651(a)(1) of $2,675 and $2,815, respectively, for petitioner's 1986 and 1987 tax years.2 After concessions, the issues for decision are: (1) Whether petitioner is entitled to a dependency exemption under section 151(a) for her daughter Sandra for the year 1987; (2) whether petitioner, for the year 1986, realized a long-term capital gain in an amount less than that determined by respondent; (3) whether petitioner, for the year 1986, is entitled to a deduction for expenses under section 212, relating to rental property, which was not allowed by respondent; (4) whether petitioner, for the year 1987, is entitled to apply, as partial payment of the tax shown as due and owing on her return, the amount of $2,899.89 held by respondent for her account, which was received by respondent pursuant to a levy, and whether petitioner is entitled to an additional credit for the proceeds of a separate levy that is not shown on respondent's transcript of account; (5) whether petitioner is ...

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