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Respondent determined a deficiency in petitioner’s Federal
income tax of $1,912 for the taxable year 1998.
The issues for decision are: (1) Whether petitioner is
entitled to two dependency exemptions for his two children,
Everton Allsopp and Aldwyn Allsopp, for the taxable year 1998;
and (2) whether petitioner is entitled to a child tax credit for
the taxable year 1998.
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. Petitioner resided in
Brooklyn, New York, on the date the petition was filed in this
case.
On December 12, 1978, Clyde Allsopp (petitioner), who is
currently an employee of the Internal Revenue Service, and Audrey
Allsopp (Ms. Allsopp) were married in Brooklyn, New York. During
the marriage, petitioner and Ms. Allsopp had three children,
Everton Allsopp (Everton), born February 27, 1979, Aldwyn Allsopp
(Aldwyn), born August 26, 1981, and Clyde Allsopp, Jr. (Clyde,
Jr.), born October 27, 1991.
On April 24, 1992, a divorce proceeding was commenced in the
Supreme Court of the State of New York, County of Kings. A
divorce was granted on May 15, 1996. On May 23, 1997, a hearing
regarding open issues was held before the Honorable Ira B.
Harkavy. These open issues were either stipulated by the parties
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