Gerald Reginald Paulson - Page 3

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          the minor child of the parties", with visitation rights accorded            
          petitioner.  Petitioner was required to pay, for the support of             
          the minor child, $456 per month, in equal installments of $228 on           
          the 1st and 15th days of each month, commencing on October 15,              
          1990.  The record does not show that, for the years in question,            
          there were any changes to this support requirement.  The decree             
          also provided that "Petitioner shall have the right to claim the            
          minor child of the parties on his federal and state tax returns             
          provided that he has been current in his child support payments             
          throughout the calendar year and is current at the time of filing           
          his tax return."  The decree further provided that petitioner's             
          former spouse "shall execute IRS Form 8332, Release of Claim to             
          Exemption for Child of Divorced or Separated Parents, in                    
          accordance with present and future Internal Revenue Code                    
          provisions and corollary state income tax forms, so that the                
          foregoing Order is fully implemented."                                      
               For each of the years at issue, petitioner claimed his                 
          daughter Candi Lynn as a dependent on his Federal income tax                
          returns.  However, the returns filed by petitioner did not have             
          attached thereto Internal Revenue Service (IRS) Form 8332 nor any           
          other statement executed by petitioner's former spouse that would           
          contain substantively the same information called for on Form               
          8332.                                                                       







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