Robert D. and Marie A. Suckley - Page 2

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               Respondent determined a deficiency in petitioner's 1992                
          Federal income tax in the amount of $1,826.                                 
               After concessions by the parties,2 the issue remaining for             
          decision is whether petitioners are entitled to claim their                 
          granddaughters, Kathy and Tiffany, and their grandson, Dennis, as           
          dependents.  Petitioners lived in Phoenix, Arizona, when they               
          filed their petition.                                                       
               Carmen Acosta (Carmen) is the daughter of Maria A. Suckley             
          and the stepdaughter of Robert D. Suckley.  Carmen is the mother            
          of five children: Donna, Kathy, Mark, Dennis, and Tiffany.                  
          During 1992, Carmen was a single parent.  She lived in a two-               
          bedroom apartment with her boyfriend and Donna, Kathy, Dennis,3             
          and Tiffany.                                                                
               Carmen was unemployed during 1992 and received welfare                 
          payments of $489 a month from Aid to Families with Dependent                
          Children (AFDC).  She also received $372 a month in food stamps.            
          Carmen testified that her boyfriend, who was employed,                      
          contributed nothing to her household expenses.                              




          2         Respondent concedes that (1) petitioners are entitled             
          to claim their grandson, Mark Acosta, as a dependent and (2)                
          petitioners are entitled to an earned income credit for Mark.               
          Petitioners concede that they are not entitled to claim their               
          granddaughter, Donna Alicea, as a dependent.                                
          3         Dennis lived with petitioners for 4-1/2 months during             
          the summer of 1992.                                                         




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