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Tymiesha’s sole source of support. During the time Tymiesha
lived with petitioner, she attended daycare daily while
petitioner was employed. On his Federal income tax return for
the year 2000, petitioner claimed a dependency exemption
deduction for Tymiesha as well as the credit under section 21 for
expenses related to dependent care services and the child tax
credit under section 24. Tymiesha did not live with petitioner
during 2001, and petitioner claimed no credits or a dependency
exemption deduction for her on his 2001 Federal income tax
return. In the notice of deficiency, respondent disallowed
petitioner’s dependency exemption deduction for Tymiesha as well
as the section 21 and 24 credits. Respondent conceded the
section 24 child tax credit at trial.
In addition to his employment with the city of Memphis and
the Housing Authority during the years at issue, petitioner was
engaged in a security business that provided bodyguards for
various entertainers such as the rapper DMX and singer Missy
Elliott. During the year 2000, petitioner traveled to Africa
with DMX as a security guard. Confusion developed in Africa when
the authorities discovered that petitioner and his traveling
entourage had neglected to obtain visas allowing them to stay in
the country. They were not allowed to remain in the country.
Petitioner contends he paid $10,000 in order for his group to
leave the country. On his Federal income tax return for 2000,
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Last modified: May 25, 2011