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otherwise indicated, all section references are to the Internal
Revenue Code in effect for the taxable years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
Respondent determined a deficiency of $1,516 in the 1998
Federal income tax of Frank E. and Gail L. Dunda and a deficiency
of $1,610 in the 1998 Federal income tax of William R. and
Deborah L. Cramer. The issue for decision is which couple is
entitled to dependency exemption deductions for 1998 for two
children of petitioner Frank E. Dunda (Dunda) and petitioner
Deborah L. Cramer (Cramer), formerly Deborah L. Dunda, during
their former marriage. Some of the facts in each case have been
stipulated and are so found.
When Dunda and his wife filed their petition and their
amended petition, they resided in Glendale, Arizona. When Cramer
and her husband filed their petition and their amended petition,
they resided in Peoria, Arizona. The Court consolidated these
cases for purposes of trial, briefing, and opinion because they
involve common questions of fact and law arising from the
separation and divorce of petitioners Dunda and Cramer.
Dunda and Cramer divorced on June 6, 1988, pursuant to the
Decree of Dissolution of Marriage (divorce decree) issued by the
Superior Court of the State of Arizona in and for the County of
Maricopa (divorce court). The divorce decree incorporated the
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