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Grace Williams declaring that she would not claim her children as
"dependents".
During the years at issue, the children lived with their
mother but visited petitioner on weekends and in the summer
months. Petitioner testified that he was often late making his
support payments, and, for several years, his Federal and State
tax refund checks were withheld and turned over to the State of
Florida for application to his arrearages. The parties stipulate
that petitioner paid aggregate child support during 1989 and 1990
of $1,879.03 and $2,199.84, respectively. Because Grace Williams
was unemployed during the years at issue, the children received
the following support from Federal and State agencies:
Program 1989 1990
Aid to families with dependent children (AFDC) $6,372 $6,352
Food stamps 3,708 5,269
Moreover, all of the children were eligible for Medicaid coverage
and benefits, and the entire family lived in subsidized housing
provided by the State.
Petitioner's 1989 Federal income tax return was due on or
before April 15, 1990. Petitioner did not file any requests for
extensions to file, and respondent received petitioner's 1989
return on February 4, 1991. On his 1989 and 1990 Federal income
tax returns, petitioner claimed each of the five children as
dependents. In the notice of deficiency, respondent determined
that petitioner was not entitled to dependency exemptions for any
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