121 T.C. No. 12
UNITED STATES TAX COURT
JEFFREY R. KING AND SABRINA M. KING, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
JIMMY R. LOPEZ AND SUZY O. LOPEZ, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 16596-02, 16868-02. Filed September 26, 2003.
L and K are the biological parents of M, who was
born in 1986. L and K have never been married to each
other. In 1988, K executed a Form 8332, Release of
Claim to Exemption for Child of Divorced or Separated
Parents, in favor of L for the taxable year 1987 and
all years thereafter. L claimed dependency exemption
deductions for M for the tax years 1987 through 1999
and attached the Form 8332 to his returns for those
years. Beginning with the taxable year 1993, K has
claimed a dependency exemption deduction for M on her
tax returns. R issued notices of deficiency to L and K
disallowing the deductions for 1998 and 1999. L and K
lived apart at all times during the years in issue. M
lived with K at all times during the years in issue.
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