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Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure. The issues for decision are whether petitioner is
entitled to deductions for alimony or dependency exemptions for
his three children during each of the years in issue, whether he
is entitled to claim head of household status for 1993, and
whether he is liable for the penalties determined by respondent.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioner resided in Lanham, Maryland, at the time that he filed
his petition.
Petitioner was previously married to Cynthia J. Baker.
During the marriage, petitioner and his then wife had three
children--Darrell Wilson and Jerrell Wilson, twins born
November 13, 1971, and Tonya Elizabeth Wilson, born August 11,
1978. Petitioner and his former wife were divorced in 1983.
The Final Judgment of Dissolution of Marriage, filed
March 2, 1983, provided in part as follows:
2. The primary physical residence of the three
minor children of the parties * * * shall be with the
Wife. The secondary physical residence of the children
shall be with the Husband.
3. Both parents shall share parental
responsibility with respect to the children, and shall
confer on all major decisions affecting the welfare of
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