Bonnie A. Broughton - Page 2

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               The sole issue is whether petitioner is entitled to claim              
          two dependency exemptions for her children.  Petitioner resided             
          in Boise, Idaho, at the time she filed her petition with this               
               The facts may be summarized as follows.  Prior to 1984,                
          petitioner was married to Gary Broughton (Gary), and two                    
          children, Cacy and Matthew, were born of the marriage.  In 1984,            
          petitioner and Gary were divorced.  Pursuant to the divorce                 
          agreement, which was incorporated into the final decree                     
          dissolving the marriage, Gary would pay $250 per month for each             
          child as child support.  Petitioner was given physical custody of           
          the children.  The agreement further provided in paragraph 18               
          that Gary "shall be allowed the exemption for both State and                
          Federal tax returns for the minor children for the year 1984, and           
          each tax year thereafter."  In 1987, Cacy was injured in an                 
          automobile accident.  On June 9, 1987, the Decree of Divorce was            
          modified to provide that Gary would maintain major medical and              
          dental insurance policies for the children and that                         
               all medical and dental expenses incurred by the minor                  
               children but not covered by insurance shall be split equally           
               between the parties and each party shall be 50% obligated on           
               said debit.  In addition, the Defendant [Gary] agrees to be            
               responsible for � of any medical expenses incurred by the              
               minor child, Cacy as a result of her accident in January               
               1987, that are not covered by insurance.                               
          Paragraph 18, relating to the tax exemptions, was not modified.             

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