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Addition to Tax
Year Deficiency Sec. 6651(a)(1)
1991 $ 896 $100
1992 1,485 184
1993 1,290 79
After concessions by petitioner, the sole issue for decision
is whether petitioner is entitled to the dependency exemption for
his daughter, under section 151, for each of the years in
question.2
Some of the facts were stipulated, and those facts, with the
annexed exhibits, are so found and are incorporated herein by
reference. Petitioner was a legal resident of Anoka, Minnesota,
at the time the petition was filed.
Petitioner was divorced from his wife, Cindy Lou Paulson, on
September 28, 1990. Petitioner and his former wife had one child
of their marriage, a daughter, Candi Lynn Paulson, who was born
on August 3, 1975. In a "Second Amended Judgment and Decree",
dated December 24, 1990 (the decree), rendered by a Minnesota
State court, petitioner's former spouse was awarded "The
permanent sole legal and physical custody, care and control of
2
The dependency exemption is the only adjustment in the
notice of deficiency that was placed at issue in the petition.
At trial, petitioner affirmed his concession of disallowed
alimony payments for the 3 years at issue, taxable unemployment
compensation income for 1992, itemized deduction adjustments for
the 3 years at issue, and the addition to tax under sec.
6651(a)(1) for the 3 years at issue.
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Last modified: May 25, 2011