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effect for the year in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency in petitioners’ Federal
income tax of $2,852 for the taxable year 2000.
The issue for decision is whether petitioners are entitled
to a dependency exemption deduction for their daughter, Beverly
Santilla (Ms. Santilla).
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
San Diego, California, on the date the petition was filed in this
case.
Petitioners filed a joint Federal income tax return for
taxable year 2000. On their return, petitioners claimed a
dependency exemption deduction for each of their three children.
In the notice of deficiency, respondent disallowed all of the
claimed dependency exemption deductions. Respondent has conceded
that petitioners are entitled to two of the deductions, but
respondent argues that petitioners are not entitled to the third
deduction for Ms. Santilla.
Ms. Santilla was born on July 25, 1977, and turned 23 years
old during the year in issue. During 2000, Ms. Santilla was a
student at San Diego Miramar College (SDMC). In the spring
semester, from January 18 through May 27, Ms. Santilla completed
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Last modified: May 25, 2011