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FINDINGS OF FACT
Some of the facts have been stipulated and are found
accordingly.
At the time of the filing of the petition in this case,
petitioner maintained a legal residence in Huntsville, Alabama.
Petitioner filed his Federal income tax returns for the taxable
years 1990, 1991, and 1992, with the Internal Revenue Service
Center in Memphis, Tennessee.
Petitioner was married at all times during the taxable years
at issue. Although petitioner and his wife had lived apart for
some years, they are not and never have been divorced.
Petitioner did not maintain as his home a household that
constituted the principal place of abode of an individual who was
a son, stepson, daughter, or stepdaughter of petitioner during
any part of any of the year 1990, 1991 or 1992.
In 1986, petitioner's mother and father immigrated from
India to the U.S. At that time, petitioner's mother received a
resident alien card. In the fall of 1989, petitioner's mother
and father applied for Government-assisted housing and were
furnished a subsidized-rent duplex in Huntsville, Alabama, in
which to live.
In October 1990, petitioner's mother began receiving
supplemental income payments from the Social Security
2(...continued)
memorandum, respondent conceded this issue.
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