Charles W. Newsom - Page 2




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               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the exhibits received into evidence            
          are incorporated herein by reference.  Petitioner resided in                
          Little Rock, Arkansas, at the time he filed his petition.                   
                                     Background                                       
               Petitioner and his wife, Longina Newsom, were legally                  
          married throughout taxable year 1997 and remained married at the            
          time of trial.  Longina Newsom is the mother of three daughters,            
          Garanece Shaw, Krissa Williams, and Shanika West.  Petitioner is            
          not the biological father of any of Longina Newsom's children,              
          all of whom were born before her marriage to petitioner.                    
          Petitioner and Longina Newsom filed separate returns for taxable            
          year 1997 and each claimed single filing status with one                    
          exemption for himself or herself and one dependency exemption.              
          Petitioner claimed Krissa Williams as his dependent, and Longina            
          Newsom claimed Garanece Shaw as her dependant.                              
               In the notice of deficiency respondent determined that                 
          petitioner's proper filing status was married filing separately             
          and did not make an adjustment with respect to petitioner's                 
          dependency exemption for Krissa Williams.  Respondent disallowed            
          petitioner's claims for head of household filing status and                 
          earned income credit.                                                       








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