Ella Louise Wooten - Page 3

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          section 151(c) for her two children, and the earned income credit           
          under section 32(a).  On each return petitioner claimed she was             
          entitled to a refund.                                                       
               In accordance with sections 6402(c) and (d), respondent                
          transferred the refund claimed by petitioner on her 1995 Federal            
          income tax return to the Mississippi Department of Human Services           
          and to the U.S. Department of Agriculture in partial satisfaction           
          of petitioner’s respective unpaid child support and food stamp              
          obligations.  In accordance with section 6402(c), respondent also           
          transferred the refunds claimed by petitioner on her 1996 and               
          1997 Federal income tax returns to the Mississippi Department of            
          Human Services in partial satisfaction of unpaid child support              
          obligations.                                                                
               Respondent thereafter examined petitioner's returns for the            
          3 years in issue and determined that she was not entitled to                
          head-of-household filing status or the dependency deductions,               
          that the earned income credit for 1995 and 1996 should be                   
          disallowed, and that the earned income credit petitioner claimed            
          for 1997 should be reduced to reflect that she was not entitled             
          to treat the children as her dependents.  Respondent issued a               
          deficiency notice to those effects, petitioner timely petitioned            
          this Court for a redetermination, and respondent filed an answer.           
          Respondent and petitioner lodged pretrial memoranda with the                
          Court, and there was a trial on the merits in which petitioner              






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