Marvin B. Hubbard - Page 5

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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