Richard J. Sarni and Susan Sarni - Page 3

                                        - 2 -                                         
               Respondent determined a deficiency in petitioners’ Federal             
          income tax for the taxable year 2000 of $920.  Hereinafter                  
          references to petitioners individually are to Mr. Sarni or Mrs.             
               The principal issues for decision are:                                 
               (1)  Whether petitioners are entitled to a dependency                  
          exemption deduction for Mrs. Sarni’s son, S.G.2  We hold that               
          they are not.                                                               
               (2)  Whether petitioners are entitled to a child tax credit            
          for S.G.  We hold that they are not.                                        
               The parties submitted this case fully stipulated pursuant to           
          Rule 122.  The stipulation of facts and the accompanying exhibits           
          are incorporated herein by this reference.                                  
               At the time that the petition was filed, petitioners resided           
          in Europe.                                                                  
               Petitioners have been married since April 2000.  Mr. Sarni             
          is a U.S. citizen, and Mrs. Sarni is a British citizen.  S.G.,              
          who is a British citizen, is Mrs. Sarni’s son and Mr. Sarni’s               
          stepson.  For the year in issue, S.G. was not Mr. Sarni’s legally           
          adopted son.                                                                

               2  We use initials for a minor child.                                  

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