Jeffrey R. King and Sabrina M. King - Page 5

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          all of Monique’s financial support in 1998 and 1999.  On the                
          basis of the expenditures for Monique established by the record,            
          the Kings provided over half of Monique’s support during these              
          years.  Mr. Lopez and Mrs. King have had only sporadic and brief            
          contact with each other since 1987, and at no time did she inform           
          him that she wanted or otherwise intended to revoke the release             
          contained in the Form 8332 that she executed on April 30, 1988.             
               On July 29, 2002, respondent issued notices of deficiency to           
          the Kings and the Lopezes for their taxable years 1998 and 1999.            
          In order to protect the Government from a potential whipsaw,                
          respondent determined that neither the Kings nor the Lopezes were           
          entitled to dependency exemption deductions under section 151.3             
          The Kings and the Lopezes timely filed petitions to this Court              
          seeking redeterminations.  Because of the common issues                     

               3Respondent also reduced the Lopezes’ child tax credit for             
          1998 and 1999 on the basis of the determination that the number             
          of their children that could be claimed as dependents was reduced           
          by one.  Resolution of this issue depends on our decision with              
          respect to the issue of which petitioners are entitled to the               
          dependency exemption deduction for Monique.                                 
               With respect to the Kings, respondent determined that they             
          were entitled to an additional child tax credit for 1998 not                
          claimed on their 1998 return; however, because respondent                   
          determined that they were not entitled to an exemption deduction            
          for Monique, the child tax credit for 1999 was reduced by $500.             
          Respondent also reduced the Kings’ earned income credit for 1998            
          on the basis of the change in the number of allowed exemptions.             
          Respondent conceded this issue before trial.  Resolution of the             
          child tax credit issue for 1999 depends on our decision with                
          respect to the issue of which petitioners are entitled to the               
          dependency exemption deductions for Monique.                                





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