Michael G. Correale - Page 3

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            County, Illinois, (the circuit court) for dissolution of their                               
            marriage pursuant to 750 Ill. Comp. Stat. Ann. 5/401 (West 1996                              
            Supp.).  On August 24, 1994, in response to some type of                                     
            application for relief filed by Mrs. Correale, the circuit court                             
            issued an order (the interim order) which at least:  (1) Required                            
            petitioner to vacate the marital premises by August 31 and                                   
            granted exclusive possession of the premises to Mrs. Correale;                               
            (2) awarded temporary custody of Michael and Robert to Mrs.                                  
            Correale; (3) awarded temporary custody of Natalyne and Christian                            
            to petitioner; and (4) established visitation rights with respect                            
            to the children.                                                                             
                  Pursuant to the interim order, petitioner and Mrs. Correale                            
            maintained separate residences from September through December                               
            1994; however, as of the close of that year, they had not entered                            
            into a written separation agreement and they had not yet been                                
            divorced.  During the last 4 months of 1994, physical custody of                             
            the children was consistent with the mandates of the interim                                 
            order.  On November 28, 1995, the circuit court entered a                                    
            Judgment of Dissolution of Marriage dissolving the marriage.  As                             
            of the date of trial in this case, certain custody matters                                   
            remained in dispute.                                                                         
                  On his 1994 Federal income tax return, petitioner claimed                              
            dependency exemption deductions for Michael, Robert, Natalyne,                               
            and Christian.  Mrs. Correale did not sign a written declaration                             





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