Ranbir Singh and Balvinder Kaur - Page 3

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               Respondent determined deficiencies in petitioners’ Federal             
          income taxes of $960 and $1,358 for the taxable years 1996 and              
               The issues for decision are:  (1) Whether petitioners are              
          entitled to a section 21 child care credit in each of the years             
          1996 and 1997; and (2) whether petitioners are entitled to a                
          dependency exemption deduction for Heche Singh in 1997.                     
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and the attached exhibits are                      
          incorporated herein by this reference.  Petitioners resided in              
          San Jose, California, on the date the petition was filed in this            
               During the years in issue, several children resided with               
          petitioners.  One of these children, Heche, who is petitioner               
          husband’s (Ranbir’s) daughter, was placed in foster care on                 
          November 8, 1996, and remained in foster care through the end of            
          1996 and through all of 1997.  In both 1996 and 1997, petitioner            
          wife (Balvinder) cared for the children at home in addition to              
          working a graveyard shift.  Balvinder’s mother, Jagdish, visited            
          petitioners in the United States in 1996 through May 3, and then            
          again in 1997 from June 26 through the end of the year.  During             
          these periods she helped care for the children.  Before, during,            
          and after the years in issue, petitioners spent approximately               

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