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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.
Sarni.
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.
Background
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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Last modified: May 25, 2011