- 2 -
opinion should not be cited as authority.
Respondent determined deficiencies in Janet E. Crowell's
1998 and 1999 Federal income taxes in the amounts of $2,820 and
$3,150, respectively. Respondent determined deficiencies in Clay
J. and Monya H. Crowell's 1998 and 1999 Federal income taxes in
the amounts of $4,424 and $2,557, respectively.
Petitioner Janet E. Crowell (Mrs. Crowell) and petitioner
Clay J. Crowell (Mr. Crowell) were formerly married to each
other. The sole issue for decision is which petitioner is
entitled to deductions for dependency exemptions under section
151 for the 2 years in question with respect to four children of
their former marriage.
Some of the facts were stipulated, and those facts, with the
annexed exhibits, are so found and are incorporated herein by
reference. At the time the petitions were filed, Mrs. Crowell's
legal residence was Clinton, Louisiana, and Mr. Crowell's legal
residence, along with that of his current wife and copetitioner,
was Livingston, Louisiana. For convenience, the two litigants
are hereafter referred to as "petitioners".
Petitioners were married to each other in August 1974. They
were divorced on April 27, 1994. They had six children:
Jon Crowell, believed to be the oldest child, whose
date of birth is not shown in the record;
Adam Crowell, whose age is also not shown in the
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011