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1991. Mr. Allen has two children. The older child graduated
college in 1996, and the younger child was in high school in
1996. After Mr. Allen moved in with petitioner in 1996, Mr.
Allen’s daughter, son-in-law, and grandson moved into the
household.
Petitioner reported wages of $14,412 and taxable pensions
and annuities of $1,180 for 1996. Petitioner also received
Social Security benefits of $2,177. Petitioner’s three children
each received Social Security benefits of $4,246.30 in 1996.
Petitioner owned the residence where the family resided.
Mr. Allen did not contribute to the expenses of the household or
support of petitioner’s children, with the exception of paying
for groceries. Mr. Allen did not care for petitioner’s children
as his own.
Mr. Allen earned wages of $48,897.12 in 1996. Mr. Allen
paid child support to his former wife for his son. Mr. Allen
also supported his daughter, son-in-law, and grandson.
On her 1996 Federal income tax return, petitioner claimed
the earned income credit under section 32.2 She also filed her
return claiming head-of-household filing status.
On December 14, 1999, respondent mailed a notice of
deficiency to petitioner for tax year 1996. Respondent
2 The record does not reflect which of her children were
claimed by petitioner as qualifying children.
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