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miscellaneous itemized deductions totaling $4,711, subject to the
2 percent of adjusted gross income limitation of section 67(a),
and Schedule C trade or business expenses of $8,799. Petitioner
attached to his returns Internal Revenue Service (IRS) Forms
8332, Release of Claim to Exemption for Child of Divorced or
Separated Parents; however, these Forms 8332 were not signed by
Ms. Mosley. Petitioner did not attach to the returns any
statement executed by Ms. Mosley that would contain substantively
the same information called for on Form 8332. The record
contains no evidence as to whether Ms. Mosley claimed the three
children as dependents on her Federal income tax returns for the
years at issue.
In the notice of deficiency, respondent disallowed the
dependency exemptions claimed by petitioner for the three
children for all years at issue. Further, respondent disallowed
$876 of the Schedule A miscellaneous itemized deductions and
$2,069 of the Schedule C trade or business expenses claimed by
petitioner for 1994.
The first issue is whether petitioner is entitled to
dependency exemptions in 1994, 1995, and 1996 for his three
children, Adam, Amanda, and Nathan. Respondent disallowed the
dependency exemptions on the ground that petitioner had not
established that he provided over one-half of the total support
of any of the children. Respondent further contends that
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