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residences. On October 13, 2003, petitioner and Ms. Godley
married. After the marriage, Ms. Godley and her son from a
previous marriage moved in with petitioner and his son, also from
a previous marriage. Petitioner and Ms. Godley were still
married at the time of trial.
Ms. Godley, separate from petitioner, filed a Federal income
tax return for the taxable year 2003. On her 2003 Federal income
tax return, Ms. Godley filed as a head of household.
Petitioner timely filed his Form 1040A, U.S. Individual
Income Tax Return, for the taxable year 2003. Petitioner filed
his 2003 Federal income tax return as a head of household and
claimed dependency exemption deductions for KM and MH.
Petitioner also claimed an earned income credit with KM and MH as
the qualifying children. Additionally, petitioner claimed a
childcare credit, a child tax credit, and an additional child tax
credit on his tax return for the taxable year 2003.
On June 7, 2004, respondent issued a notice of deficiency
denying petitioner (1) head of household filing status, (2) the
claimed dependency exemption deductions, (3) the claimed earned
income credit, (4) the claimed childcare credit, and (5) the
claimed child tax credits. However, as previously noted, before
trial respondent conceded that petitioner was entitled to the
dependency exemption deductions, childcare credit, and child tax
credits for the taxable year 2003.
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