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mailed to Mr. Pilgram a return for his signature, which he signed
and filed.
On her income tax return, Form 1040, for 1998, petitioner
claimed head-of-household filing status, naming Randy as the
qualifying person. Petitioner did not claim a deduction for a
dependency exemption for her son. Petitioner reported total
income in the amount of $12,927 and tax in the amount of $596.
Petitioner did not claim a child tax credit, see sec. 24(a), but
she did claim a credit for child care expenses in the amount of
$596, thereby reducing her tax liability to zero. Petitioner
also claimed an earned income credit in the amount of $2,165,
naming Randy as the qualifying child.
On his income tax return, Form 1040, for 1998, Mr. Pilgram
claimed married-filing-separate filing status. Mr. Pilgram also
claimed a deduction for a dependency exemption for Randy, as well
as a child tax credit. He did not, however, claim a credit for
child care expenses or an earned income credit.
Upon audit, respondent determined a deficiency in
petitioner’s income tax in the amount of $2,761.2 In determining
the deficiency, respondent: (1) Adjusted petitioner’s filing
status from head-of-household to married filing separately; (2)
2 The record does not disclose whether respondent examined
Mr. Pilgram’s return, and, if so, whether any deficiency was
determined.
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Last modified: May 25, 2011