Debra D. McNair - Page 5

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          children, Shawnda Swain and Ebony Redmond, were the children of             
          petitioner’s niece.  The other child, Tanisha Moore, was the                
          child of a person petitioner described as a friend or “partner in           
          crime” of her niece.  Petitioner testified that Shawnda Swain and           
          Ebony Redmond stayed with her for approximately 6 to 8 months in            
          1999 and 2000 and that Tanisha Moore lived with her for 5 to 6              
          months in 1999.  Petitioner admitted that Tanisha Moore did not             
          live with her in 2000 and that she should not have claimed a                
          dependency exemption deduction for her in 2000.                             
               In claiming the dependency exemption deductions for the                
          children, petitioner incorrectly described her relationship to              
          them.  On her 1999 return, petitioner stated that Shawnda Swain             
          and Tanisha Moore were her foster children and that Ebony Redmond           
          was her son.  On her 2000 return, petitioner incorrectly stated             
          that Tanisha Moore was her daughter, that Shawnda Swain was her             
          foster child, and that Ebony Redmond was her son.                           
               In addition to the dependency exemption deductions,                    
          petitioner also claimed various child tax credits for Shawnda               
          Swain, Ebony Redmond, and Tanisha Moore.  On her 1999 return,               
          petitioner claimed a credit for child and dependent care expenses           
          of $960, a child tax credit of $889, and an additional child tax            
          credit of $611.  On her 2000 return, petitioner claimed a child             
          tax credit of $1,076 and an additional child tax credit of $424.            








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