James B. Golden, Jr. and Rayliene Golden - Page 2

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               Respondent determined a deficiency in petitioners' Federal             
          income tax for 1995 in the amount of $1,400.                                
               After a concession by respondent,2 the issue remaining for             
          decision is whether petitioners are entitled to an exemption                
          deduction for Miguel Angel Castellon Acosta (Miguel).                       
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and attached exhibits are incorporated             
          herein by this reference.  Petitioners resided in South Windsor,            
          Connecticut, on the date the petition was filed in this case.               
               Miguel arrived in the United States on December 6, 1995, as            
          a refugee from a migrant camp in Guant�namo Bay, Cuba.  He was              
          sponsored by the Office of Migrant Services of the United States            
          Catholic Conference of the Archdiocese of Hartford, Connecticut.            
          Miguel was 20 years old when he arrived in the United States.               
          His only belongings were the clothes he was wearing.                        
               Petitioners welcomed Miguel into their home on December 6,             
          1995, and he presently still resides there.  Since his arrival in           
          the United States, Miguel has obtained his graduate equivalency             
          diploma from East Catholic High School, has found a job that                
          provides him with medical benefits, and currently attends                   
          Manchester Community College.                                               
               On the advice of their accountant, petitioners claimed an              
          exemption deduction for Miguel on their 1995 return.                        

          2         Respondent concedes that petitioners are entitled to a            
          dependency exemption deduction for James Aiello, petitioner                 
          wife's son from a previous marriage.                                        



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