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Respondent determined a deficiency in petitioner’s Federal
income tax for the taxable year 1997 in the amount of $2,673.
The issues for decision are as follows:
(1) Whether petitioner is entitled to dependency exemptions
for his two daughters. We hold that he is not.
(2) Whether petitioner is entitled to head-of-household
filing status. We hold that he is not.
(3) Whether petitioner is entitled to an earned income
credit. We hold that he is not.
Background2
Some of the facts have been stipulated, and they are so
found. Petitioner resided in Keystone Heights, Florida, at the
time that his petition was filed with the Court.
A. Petitioner’s Marriage and Divorce
In June 1993, petitioner and Lee Ellen Phillips (Ms.
Phillips) were married in Duval County, Florida. Three years
later, in June 1996, the couple separated. Later that month,
petitioner commenced divorce proceedings. On December 22, 1997,
the circuit court for Duval County, Florida (the Duval County
court) entered a Final Judgment of Dissolution of Marriage (the
divorce decree).
2 At trial, we deferred ruling on certain evidentiary
objections (relating principally to relevancy) that respondent
reserved in the stipulation of facts. We now overrule those
objections.
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