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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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