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the children. Section 3.17 of the Order, provided that “Tax
exemptions for the children shall be allocated as follows:
BRANDT NOBLE CASTLETON is awarded tax exemptions unless the
mother becomes employed full time, then exemptions shall be
split.” Petitioner and Ellen ultimately agreed that petitioner
would claim dependency exemptions on his tax returns for Shenara,
Keturah, and Adara, while Ellen would claim the exemptions for
Arthur and Aaron.
On his 1998 and 1999 returns, petitioner claimed dependency
exemptions for Shenara, Keturah, and Adara and child tax credits.
In a supplemental stipulation, the parties agreed that petitioner
is entitled to the dependency exemptions claimed on his 1998 and
1999 returns but did not address the child tax credits.
Charitable Contributions
Petitioner is a Microsoft-certified professional. After his
divorce, petitioner decided to divest himself of the “garage
full” of equipment he had acquired through his studies of
computers, software, office equipment, and office equipment
repair. Petitioner discussed this decision with his return
preparer, Willie Hughes. Mr. Hughes, who was affiliated with
RRS, recommended that petitioner donate his equipment to the
organization.4 At some point during the years at issue,
4While the parties dispute the true nature of RRS, they have
stipulated that RRS did not apply for or receive an exemption
(continued...)
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