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Respondent determined a deficiency in petitioner's Federal
income tax for 1998 in the amount of $2,134.
After a concession by respondent,2 the issues for decision
are as follows:
(1) Whether petitioner is entitled to deductions for
dependency exemptions for her two sons. We hold that she is.
(2) Whether petitioner is entitled to a child tax credit in
respect of her two sons. We hold that she is.
Background
Many of the facts have been stipulated, and they are so
found.
At the time that the petition was filed, petitioner resided
in Santa Maria, California.
A. Petitioner’s Marriage and Children
In May 1980, petitioner and Dean William Anker (Mr. Anker)
were married in West Point, New York. The couple had two sons:
Francis Gregory Anker, who was born in June 1982, and Daniel
Thomas Anker, who was born in January 1984 (collectively, the
children or petitioner’s sons).
B. Petitioner’s Divorce
In or about 1984, petitioner and Mr. Anker experienced
marital discord, and divorce proceedings were commenced. Both
2 Respondent concedes that petitioner’s filing status for
1998 is head-of-household.
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