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Petitioner was granted a divorce in 1999, but the divorce
was appealed by petitioner and his wife. The current status of
the appeal is unknown, but petitioner’s wife has remarried.
Petitioner sees his two youngest children once a month and sees
the two older children much less frequently. He continues to pay
support and provide medical insurance for the children; he paid
for medical insurance for his wife through 1999. He has also
paid for other expenses for the children over the years,
including clothing expenses.
Petitioner filed a Federal income tax return for taxable
year 1998 with the filing status married filing separately. For
each of his four children, petitioner claimed a dependency
exemption deduction and a child tax credit. Petitioner reported
the following tax liability:
Pension and annuity income $31,246
Itemized deductions (5,214)
Personal exemption deduction (2,700)
Dependency exemption deductions (10,800)
Taxable income 12,532
Tax from tax tables 1,879
Child tax credits (1,600)
Tax 279
Only what appears to be the cover sheet from the statutory
notice of deficiency, without attachments, was introduced into
evidence. Consequently, we do not have before us the rationale
for respondent’s adjustments. The petition, along with the
parties’ arguments and testimony, center around petitioner’s
entitlement to the four dependency exemption deductions.
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