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Respondent determined deficiencies in petitioners’ Federal
income taxes of $960 and $1,358 for the taxable years 1996 and
1997.
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
case.
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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