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increased Mr. Anker’s monthly child support obligation from $400
to $593.41, effective September 1, 1996.
E. Petitioner’s Federal Income Tax Return for 1998
Petitioner timely filed a Federal income tax return for
1998. On her return, petitioner designated her filing status as
head-of-household, and she claimed her two sons as dependents.
Petitioner also claimed a child tax credit in respect of her
sons.
F. The Notice of Deficiency
In the notice of deficiency, respondent determined that
petitioner was not entitled to deductions for dependency
exemptions because the divorce decree authorized Mr. Anker to
claim those deductions. Respondent also determined that
petitioner was not entitled to the child tax credit. Finally,
respondent determined that petitioner’s filing status is single.
However, as previously mentioned, respondent conceded at trial
that petitioner’s filing status is head-of-household, as
originally designated by petitioner on her return.
Discussion
A. Deductions for Dependency Exemptions
Section 151(a) authorizes deductions for the exemptions
provided by that section. In particular, section 151(c)(1)
provides an exemption for each of a taxpayer’s dependents as
defined in section 152.
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