Derrick Elkins - Page 4

                                        - 3 -                                         
               Petitioner filed Federal income tax returns for taxable                
          years 1999 and 2000.  In each return, petitioner filed as a “head           
          of household” and claimed dependency exemption deductions.  For             
          1999, petitioner claimed dependency exemption deductions for                
          Jaleshia Stackhouse (Jaleshia), Caletta Pressley (Ms. Pressley),            
          and Tyra Postles (Tyra).4  Jaleshia is petitioner’s daughter, who           
          was 9 years old in 1999 and who lived with petitioner during the            
          years in issue.  Petitioner described Ms. Pressley as “a friend”,           
          who was 32 years old in 1999 and who, along with Tyra, moved in             
          with petitioner for about 9 months, starting after February 1999.           
          Ms. Pressley is the biological mother of Tyra, who was born                 
          February 15, 1999.                                                          
               For 2000, petitioner claimed dependency exemption deductions           
          for Sabrina Stackhouse (Ms. Stackhouse) and Jaleshia.  Ms.                  
          Stackhouse, who was 31 years old in 2000, is the biological                 
          mother of Jaleshia.  She moved in with petitioner sometime after            
          March 2000.  Petitioner testified that he was not married to Ms.            
          Stackhouse during the relevant taxable years.                               







               4  According to respondent, no one else, other than                    
          petitioner, claimed the dependency exemption deductions with                
          respect to Jaleisha, Ms. Pressley, or Tyra for the years in                 
          issue.  Moreover, none of them filed returns for the years in               
          issue.                                                                      




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