Michael Kevin and Vickie P. Boltinghouse - Page 3

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                    We agree that I [petitioner] will claim Brandi and Lisa           
               will claim Brittany as dependents on our separate [sic] tax            
               returns.  I agree Lisa can claim all interest on the house             
               on her tax return.  Pending when the divorce is final, we              
               agree to file a joint tax return for 1990 and possibly 1991.           
               If a refund is due, Lisa will reeive [sic] 70% and Iwill               
               [sic] receive 30%.  If a payment is due we agree to split              
               the cost 50-50.                                                        
          At the time that the agreement was signed, both petitioner and              
          Ms. Rogers intended that the provision regarding the dependency             
          exemption deductions would apply until the children were either             
          18 years old or, if the children were enrolled as full-time                 
          students, 24 years old.  The agreement also provided details                
          concerning such matters as the division of marital property and             
          the payment of child support.                                               
               Petitioner and Ms. Rogers were divorced pursuant to a final            
          decree executed by the Family Court of the State of Delaware,               
          Sussex County, on February 5, 1991.  The decree did not                     
          incorporate the separation agreement, nor did it provide any                
          details regarding such matters as property settlement, custody of           
          the children, payment of child support, or entitlement to the               
          dependency exemption deductions.  The decree referenced only an             
          Order of the Master which had reflected the minimal findings                
          necessary for a divorce under Delaware law.                                 
               Petitioner and his current wife, petitioner Vickie P.                  
          Boltinghouse, filed a joint Federal income tax return for taxable           
          year 1998.  On their return, they claimed a single dependency               
          exemption deduction and child tax credit for Brandi.  They                  





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