Thomas B. McCarthy, Jr. and Janice R. McCarthy - Page 3

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                  just ended to enable Husband to attach it to his income                             
                  tax returns.                                                                        
                  A judgment of divorce was entered by the Circuit Court of                           
            Montgomery County, Maryland (hereinafter the county court), on                            
            August 1, 1989.  The March 1989 agreement was incorporated in the                         
            judgement of divorce.                                                                     
                  Subsequent to the divorce decree petitioner married Janice                          
            R. McCarthy.  Rosalie McCarthy also remarried.  Following the                             
            entry of the divorce decree, petitioner and Rosalie McCarthy had                          
            ongoing disputes concerning support payments, visitation rights,                          
            and other provisions of the March 1989 agreement.  Petitioner and                         
            Rosalie McCarthy appeared in the county court on several                                  
            occasions in an attempt to resolve some of their disputes.  The                           
            county court issued a number of orders relating to some of the                            
            disputed issues.  At some point in 1991, the county court                                 
            determined petitioner to be in arrearage in child support                                 
            payments and the county court imposed earnings withholdings                               
            against petitioner's employer.  In early 1992, the county court                           
            reversed its prior ruling and no longer required earnings                                 
            withholdings.                                                                             
                  For the taxable year 1991, Rosalie McCarthy was the                                 
            custodial parent of the three children.  She did not execute a                            
            written declaration indicating that she was not claiming the                              
            children as dependents.  In fact, Rosalie McCarthy claimed the                            
            children as dependents on her 1991 Federal income tax return.                             





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