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Fortune. Mr. Fortune was employed during 1998, but petitioner
did not secure employment. At the end of August 1998, petitioner
and Simeon moved in with petitioner’s mother, while the youngest
two children remained with Mr. Fortune.
Petitioner, Simeon, and Dequane lived with petitioner’s
mother through the end of the year. Petitioner secured
employment by the end of November 1998, and her mother worked
during the period at issue. Simeon lived with petitioner for all
of 1998.
Petitioner earned wages of $7,186 in 1998. Petitioner also
received $5,064 in housing subsidies from HUD for herself and her
four children. In addition, petitioner and her four children
received $2,372 from AFDC and $2,998 in food stamps. Further,
Simeon’s father, Simeon Gemaele Thomas, paid $396.68 of child
support in 1998.
On her 1998 Federal income tax return, petitioner claimed
(1) a dependency exemption deduction for Simeon and (2) an earned
income credit with Simeon listed as a qualifying child.
Petitioner also filed her return claiming head-of-household
filing status.
In the notice of deficiency to petitioner, respondent
disallowed the dependency exemption deduction and earned income
tax credit. Respondent alleges that petitioner failed to meet
the requirements for the dependency exemption deduction and did
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