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married and filed a joint Federal income tax return. In 1992,
petitioners divorced, and Stephen A. Lenn (petitioner) filed a
separate return and elected the "Head of household" filing
status. Petitioner Ksenia Lenn is a party to this proceeding
only for the 1991 tax year.
Petitioner has a son, Daniel Lenn, from a previous marriage.
Before 1991, Daniel lived with his mother in Portland, Maine. In
1982, when Daniel was in the first grade, he was diagnosed with a
learning disability. Daniel is disabled within the meaning of
the Individuals with Disabilities Education Act (IDEA), Pub. L.
91-230, sec. 601, 84 Stat. 175 (1970), as amended. The IDEA
requires that in order to receive Federal funding for education
of handicapped children, a State must offer to a disabled child
an individualized educational program (IEP) that addresses the
child's individual needs in a way that is reasonably calculated
to enable the child to receive educational benefits. 20 U.S.C.
sec. 1400(c) (1970), as amended. Daniel attended public school
through the eighth grade in the Portland School District under a
series of IEP's, one for each school year, pursuant to the IDEA.
Although Daniel was a special education student, he attended
regular classes with nondisabled students for most of the school
day. Because of his learning disability, Daniel had poor
interpersonal skills and had difficulty interacting with his
classmates, who frequently teased and ostracized him.
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