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Ms. Caddle during the year that Ms. Caddle’s work schedule
changed.
Ms. Caddle testified and confirmed that her work schedule
changed in 2000. According to Ms. Caddle, however, her daughter
moved in with her before then. Ms. Caddle determined the time
frame based upon the completion of her new house, which she moved
into prior to 2000.
Petitioner’s daughter also testified. She admitted that she
was unsure of the year that she moved in with her mother, but
recalled that it was during the year that her mother switched
from working afternoons and evenings to working days.
After careful consideration of all of the evidence in this
case, including the handwritten note authored by petitioner’s
daughter, we are satisfied that petitioners’ version of the
events is correct. That being the case, we find that for
purposes of section 152(e), petitioner is treated as the
custodial parent of his daughter for 1998. It follows that he is
entitled to a dependency exemption deduction for her for that
year, and respondent’s determination to the contrary must be
rejected.
To reflect the foregoing,
Decision will be entered
for petitioners.
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Last modified: May 25, 2011