Emmanuel I. Nwachukwu - Page 3




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          The stipulated facts and the accompanying exhibits are                      
          incorporated into our findings by this reference.  At the time              
          the petition in this case was filed, petitioner resided in San              
          Leandro, California.                                                        
               Petitioner has a college degree in finance and was employed            
          as a tax auditor by the State Board of Equalization of California           
          during the year at issue.                                                   
               Petitioner claimed a dependency exemption deduction for two            
          children--his son, Bradley, and daughter, Michelle.  Bradley                
          lived with petitioner until sometime in June, after which time he           
          lived with his mother in Texas.  After Bradley went to live with            
          his mother, petitioner did not provide any financial support for            
          the child.                                                                  
               On his return, petitioner reported that he paid $5,760 for             
          medical expenses and $4,800 for child care for his two children.            
          Respondent disallowed these deductions for lack of substantiation           
          of the amounts claimed and because petitioner did not establish             
          that he had two dependent children.                                         
               As a result of an investigation, petitioner was terminated             
          from his job at the State Board of Equalization sometime during             
          May of 1995.  Upon termination, petitioner's briefcase was taken            
          from him for a while, and he was not allowed back inside the                
          building.                                                                   
               After losing his position at the State Board of                        






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