Conrad Fitzgerald Lewis - Page 4

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          incorporated herein by this reference.  Petitioner resided in               
          Hopkins, South Carolina, on the date the petition was filed in              
          this case.                                                                  
               In March of 1995, petitioner and Paula B. Lewis (Ms. Lewis)            
          were married.  Ms. Lewis had a child, KM, from a previous                   
          relationship.  Petitioner and Ms. Lewis had two children during             
          their marriage, BL and JL.  Petitioner and Ms. Lewis also had two           
          foster children, BW and DD, in their custody during the taxable             
          years in issue.  DD is the only child at issue in the present               
          case.  On June 3, 1999, the South Carolina Department of Social             
          Services issued to petitioner and Ms. Lewis a license to conduct            
          a foster family boarding home under the provisions of Act Number            
          334, Section 3, enacted March 10, 1986.  DD was placed with                 
          petitioner and Ms. Lewis by Growing Home, a branch of South                 
          Carolina Social Services, from April 9, 2000, through October 1,            
               Petitioner and Ms. Lewis separated in taxable year 2000.  At           
          that time, petitioner moved out of their house.  At the time of             
          trial, petitioner and Ms. Lewis were still trying to reconcile,             
          but were not formally divorced.                                             
               Petitioner and Ms. Lewis purchased their house in 1999 using           
          their combined funds.  The house was titled solely in Ms. Lewis’s           
          name.  Ms. Lewis claimed a deduction for the home mortgage                  

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