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Respondent determined deficiencies in petitioner’s Federal
income taxes for 1995, 1996, and 1997 in the amounts of $3,608,
$2,846, and $3,505, respectively. The issues for decision are:
(1) Whether petitioner is entitled to dependency exemption
deductions for his two sons; (2) whether petitioner is entitled
to head of household status; and (3) whether petitioner is
entitled to earned income credits.
Some of the facts in this case have been stipulated and are
so found. The stipulation of facts and the exhibits received
into evidence at trial are incorporated herein by this reference.
At the time the petition was filed, petitioner lived in Seattle,
Washington.
Petitioner has two minor sons: Thaddeus S. Hollingsworth,
born on November 24, 1982, and Malcolm R. Hollingsworth, born on
July 10, 1984 (collectively the children). Petitioner and Celia
Smith (Ms. Smith), the children’s mother, were never married.
They agreed, however, that Ms. Smith would have legal custody of
the children. They further agreed that the children would stay
with petitioner on the weekends and during the summer months.
Under the supervision of the Department of Child Services,
petitioner is required to pay child support of approximately $400
per month.1
1 The record shows that petitioner has been in arrears in
all years in issue.
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