- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011