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Respondent determined a deficiency of $1,035 in petitioners’
Federal income tax for 2001. Petitioner Danny M. Shrader
(Shrader) did not appear at trial, was deemed in default, and
will have the issue decided against him for that reason. See
Rules 123(a) and 149(a). Petitioner Alicia J. Shrader
(petitioner) appeared and testified. The issue for decision is
whether petitioners are entitled to a dependency exemption during
2001 for Shrader’s daughter, ANS.
Background
Shrader is the former husband of petitioner and the father
of ANS from a prior relationship. During 2001, ANS did not
reside with petitioners at any time. During 2001, petitioners
made $3,804.75 in child support payments to the State of
Washington Division of Child Support on behalf of ANS. On their
Form 1040, U.S. Individual Income Tax Return, for 2001,
petitioners claimed a dependency exemption for ANS. In the
notice of deficiency, respondent disallowed the dependency
exemption, determining that Shrader was not the custodial parent
of ANS during 2001 and that petitioners had not provided
documentation necessary to establish their eligibility to claim
her as a dependent or their provision of more than 50 percent of
her total support during 2001. The explanation in the notice of
deficiency stated that “the information available to the I.R.S.
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