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For all of 1998, Samantha, then 13 years old, resided with
her mother, Ms. Thompson.
From January through April of 1998, John, then 18 years old,
lived with his mother. For the remainder of 1998, John lived
with petitioner.
On her 1998 Federal income tax return, Ms. Thompson claimed
a dependency exemption and a child tax credit with respect to
Samantha.
On his 1998 individual Federal income tax return to which he
attached a copy of the above divorce decree, petitioner reported
taxable income of $49,904, and petitioner claimed a dependency
exemption and a child tax credit with respect to Samantha.
On their separate tax returns for 1998, neither petitioner,
nor Ms. Thompson, claimed John as a dependent.
On audit, respondent denied petitioner’s claimed dependency
exemption and child tax credit with respect to Samantha. At
trial, respondent concedes that for 1998 petitioner is entitled
to change his filing status from single to head of household and
that petitioner is entitled to a dependency exemption with
respect to John.
OPINION
Ordinarily, a taxpayer may claim a dependency exemption with
respect to a child for a particular year if the taxpayer provides
more than half of the child’s support in the year for which the
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