Clyde Everton Allsopp - Page 7

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          of signature; (3) the custodial parent’s Social Security number;            
          (4) the noncustodial parent’s name; and (5) the noncustodial                
          parent’s Social Security number.                                            
               Petitioner argues that he attached a copy of the December 2,           
          1997, decision to his return and thus met the requirements of               
          section 152(e)(2).  Respondent argues that the decision was not             
          attached to petitioner’s return, and, in the alternative, even if           
          the decision had been attached to the return, that it does not              
          meet the requirements of section 152(e)(2) because (a) the                  
          decision is conditional, (b) the decision does not state with               
          specificity the applicable tax year or years for which petitioner           
          is entitled to the dependency exemption, and (c) the decision is            
          neither signed by the custodial nor noncustodial parent and as              
          such does not satisfy the statutory requirements of section                 
          152(e)(2).                                                                  
               Upon the basis of the record, this Court finds that                    
          petitioner has not shown that he attached the decision to his               
          1998 Federal income tax return as required by section                       
          152(e)(2)(B).  However, even if petitioner had proven that the              
          decision was attached to his 1998 Federal income tax return, this           
          Court finds that the decision does not meet the requirements of             
          section 152(e)(2).                                                          
               In the instant case, petitioner admits that he was Everton             
          and Aldwyn’s noncustodial parent during the taxable year 1998.              






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