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Respondent determined a deficiency of $1,825 in petitioners’
Federal income tax for 1999. The sole issue for decision is
whether Tammy L. McNichol (petitioner) released to her former
spouse, John F. McNichol (Mr. McNichol), under section 152(e)(2),
for the year 1999, the dependency exemption deductions for
petitioner and Mr. McNichol’s two children.
Some of the facts were stipulated, and those facts, with the
accompanying exhibits are so found and are made part hereof. At
the time the petition was filed, petitioners were legal residents
of Gladwin, Michigan.
Petitioner and Mr. McNichol were formerly married to each
other and were divorced in November 1990. Two daughters were
born of that marriage in 1987 and 1989. Petitioner thereafter
married Ricky C. Hutchinson. They filed a joint Federal income
tax return for 1999. Mr. McNichol, petitioner’s former spouse,
also remarried.
On their joint Federal income tax return for 1999,
petitioners claimed the two daughters as dependents. Likewise,
Mr. McNichol and his spouse claimed the two daughters as
dependents. In the notice of deficiency, respondent disallowed
the two dependency exemption deductions claimed by petitioners
for her two daughters.2 The basis for the disallowance is
2
The record is unclear whether respondent also disallowed the
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