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Respondent determined deficiencies of $2,199, $2,100, and
$2,267 in petitioner's Federal income taxes for 1994, 1995, and
1996, respectively.
The issues for decision are: (1) Whether petitioner is
entitled to dependency exemptions for 1994, 1995, and 1996 for
his daughter, Amanda Elder, and for his sons, Adam Elder and
Nathan Neal; (2) whether petitioner is entitled to itemized
deductions for 1994 in excess of an amount allowed by respondent;
and (3) whether petitioner is entitled to deductions for trade or
business expenses for 1994 in excess of an amount allowed by
respondent.
Some of the facts were stipulated, and those facts, with the
annexed exhibits, are so found and are incorporated herein by
reference. At the time the petition was filed, petitioner's
legal residence was Naples, Florida.
Petitioner was previously married to Debra Lynn Mosley (Ms.
Mosley). Two children were born to the couple prior to marriage,
namely, Adam Elder (Adam), born May 29, 1986, and Amanda Elder
(Amanda), born April 30, 1988. A third child was born to the
couple during their marriage; namely, Nathan Neal (Nathan), born
May 18, 1990. Petitioner and Ms. Mosley were divorced on
March 11, 1992, pursuant to a Decree of Dissolution (divorce
decree) by a Kentucky State court, the Fayette Circuit Court
(Fayette Circuit Court). In the divorce decree, petitioner and
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