Randall Albert Fritscher - Page 3




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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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