Michael S. and Christine R. Norwood - Page 2




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          1511 and to child tax credits under section 24 for petitioner               
          Christine Norwood’s two sons.                                               
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.  The          
          stipulation of facts and the attached exhibits are incorporated             
          herein by this reference.                                                   
               Petitioners resided in Walhalla, South Carolina, at the time           
          their petition was filed with this Court.  Christine R. Norwood             
          (petitioner) was formerly married to Thomas V. Harbin.  Petitioner          
          and Mr. Harbin had three children:  Cassandra, born July 23, 1978;          
          Nicholas, born December 10, 1981; and Jason, born February 13,              
          1983.  Petitioner and Mr. Harbin separated in September 1988; they          
          were divorced in October 1989.                                              
               On May 23, 1989, the Family Court, State of South Carolina,            
          County of Oconee (the Family Court), issued an order (the May 23,           
          1989, order) that incorporated an agreement between the parties.            
          At that time, both parties were employed, but the possibility               
          existed that Mr. Harbin might be laid off and become disabled due           
          to pending back surgery.                                                    
               The May 23, 1989, order provided, among other things, that             
          petitioner would maintain medical insurance coverage for her                
          children and petitioner and Mr. Harbin would divide equally all             


               1    Section references are to the Internal Revenue Code in            
          effect for the year at issue.                                               





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