Clyde Everton Allsopp - Page 5

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          is not an issue in the present case.  Petitioner claimed the                
          child tax credit in the amount of $800, $400 of which applied to            
          Sheclyia.  Respondent allowed the exemption and child tax credit            
          with regard to Sheclyia.                                                    
               Ms. Allsopp claimed Everton and Aldwyn as her dependents for           
          the 1998 taxable year.  During the 1998 taxable year, petitioner            
          did not have physical custody of Everton, Aldwyn, and Clyde, Jr.            
          Neither petitioner nor Ms. Allsopp executed or signed a Form                
          8332, or a similar declaration for the 1998 tax year.                       
               Respondent issued a notice of deficiency to petitioner in              
          which respondent disallowed two of petitioner’s claimed                     
          exemptions for the 1998 taxable year as well as a portion of the            
          child tax credit in the amount of $400.                                     
                                     Discussion                                       
          I.  Dependency Exemption Deduction                                          
               A dependency exemption generally is allowed under section              
          151(a) for each dependent of a taxpayer.  Sec. 151(a), (c)(1).              
          In general, a child of a taxpayer is a dependent of the taxpayer            
          only if the taxpayer provides over half of the child’s support              
          for the taxable year.  Sec. 152(a).  A special rule applies to              
          taxpayer-parents (a) who are divorced, who are separated, or who            
          live apart for at least the last 6 months of the calendar year,             
          and (b) whose child is in the custody of one or both parents for            
          more than half of the year.  Sec. 152(e)(1).  Under this rule, if           






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