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obligations regarding child support, health insurance,
and payment for uncovered medical expenses.
* * * * * * *
ARTICLE VI. General Provisions
1. [Petitioner] and [Ms. Beck] shall, upon demand
of the other party, execute any and all instruments and
documents that may be reasonably necessary to make
effective the provisions of this Agreement * * *.
The Agreement was incorporated into a “Judgment for
Dissolution of Marriage” by the Circuit Court of the 17th
Judicial Circuit, County of Winnebago, State of Illinois.
Petitioner and Ms. Beck were divorced on August 27, 1997.
During the year in issue, Jonathan resided with petitioner
for about a month in January 1999, and Jennifer resided with
petitioner for about a month and a half during the summer. For
the remainder of 1999, and indeed the majority of the taxable
year, Jonathan and Jennifer resided with Ms. Beck.
Petitioner filed a timely Federal income tax return for the
1999 taxable year. Petitioner filed as “head of household” and
claimed a child tax credit of $350. Petitioner also claimed
dependency exemption deductions for Jonathan and Jennifer, but
did not attach a written declaration or Form 8332, Release of
Claim to Exemption for Child of Divorced or Separated Parents,
executed by Ms. Beck. Petitioner asked Ms. Beck to sign a Form
8332 for the taxable year 1999, but she refused to do so.
Respondent, in a notice of deficiency dated October 16, 2001,
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