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Respondent determined a deficiency of $2,914 in petitioners’
2002 Federal income tax. After a concession by respondent,1 the
issues for decision are: (1) Whether petitioners are entitled to
dependency exemption deductions for petitioner husband’s son and
daughter, and (2) whether respondent is estopped from disallowing
the claimed dependency exemption deductions.
Background
Some of the facts have been stipulated and are so found.
Petitioners are married and resided in Westland, Michigan, at the
time their petition was filed. Unless otherwise indicated, all
references to petitioner are to Tommie Wilder.
Petitioner and Sharon Williams have two children, their son
BW and daughter TW (collectively, “the children”).2 Petitioner
and Ms. Williams were never married and did not live together in
2002. The children lived with Ms. Williams during that year,
although petitioner provided most of the children’s support.
Petitioners claimed the children as dependents on their
joint 2002 Federal income tax return. Petitioners did not attach
to their return a Form 8332, Release of Claim to Exemption for
Child of Divorced or Separated Parents, executed by Ms. Williams.
1 Petitioners claimed dependency exemption deductions for
four children. Respondent concedes petitioners are entitled to
such deductions for two of the children.
2 Petitioner’s son is a minor. Although the record is not
entirely clear, it appears petitioner’s daughter may also be a
minor. We therefore use only the children’s initials.
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Last modified: May 25, 2011