Pacita Palermo Reyes - Page 4

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               For the year in issue, petitioner earned $25,237 in taxable            
          wages.  Petitioner resided, by herself, in a three-bedroom house            
          with an attached garage, which was converted into a fourth                  
          bedroom and a bathroom.                                                     
               Ms. Embry lived in a three-bedroom house with her five                 
          children.  Ms. Embry did not own a car.  She was unemployed, and            
          she received $900 per month in child support from Mr. Embry.  Ms.           
          Embry’s children were covered by Mr. Embry’s medical insurance              
          program through the U.S. Navy.  Ms. Embry paid $540 per month for           
          rent, during taxable year 2002, and received approximately $300             
          per month in food stamp assistance, along with free school                  
          lunches for some of her children, including CME and CJE.                    
               In the year at issue, petitioner provided financial                    
          assistance to Ms. Embry and petitioner’s grandchildren.                     
          Petitioner paid for the telephone service in Ms. Embry’s house,             
          which was registered in petitioner’s name.  At various times                
          throughout 2002, petitioner bought clothing, shoes, and dinners             
          for all of her grandchildren.  Further, petitioner paid for and             
          accompanied her grandchildren when they traveled to Busch                   
          Gardens.  Petitioner provided rides to stores and to recreational           
          events because Ms. Embry did not own a car.  Periodically,                  
          petitioner bought laundry detergent, dishwashing liquid,                    
          toothpaste, paper towels, toilet paper, and many other household            
          necessities for Ms. Embry and petitioner’s grandchildren.  During           






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