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Respondent determined deficiencies of $742 and $3,068 in
petitioner’s 1997 and 1998 Federal income taxes, respectively.
The issue is whether petitioner is entitled to dependency
exemption deductions for any of his children during 1997 and
1998. Petitioner resided in Milford, Maine, at the time he filed
the petition in this case.
Petitioner and his former wife were divorced in 1990. From
what is in the record, in the earlier years the divorce was not a
pleasant affair. Petitioner had three children from this
marriage (Tracey, Meghan, and Candace). The original divorce
decree, dated September 21, 1990, provides:
The Court awards to the parties shared parental rights
and responsibilities as to the minor children * * *. The
primary physical residence of the children shall be with the
* * * [former wife]. * * * [Petitioner] shall have the
right to be visited by the minor children at all reasonable
times * * *.
The divorce decree was amended on January 7, 1992, to provide
that
“reasonable times” * * * shall be defined to include at
least that period during the three consecutive days off
* * * that * * * [petitioner] has in his current employment
schedule * * *.
It is not disputed that petitioner paid more than half of
the support for the children during the years before the Court.
The original divorce decree provided that petitioner would pay
$148.72 per week for child support. On January 28, 1993, by
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