Nasser and Scottiann Zamani - Page 3

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               Respondent determined a $1,604 deficiency in petitioners’              
          2003 Federal income tax.  The issue for decision is whether                 
          petitioners are entitled to a deduction for dependency exemptions           
          for petitioner husband’s son and daughter from a prior marriage.            
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts with attached exhibits, and additional             
          exhibits admitted at trial, are incorporated herein by this                 
          reference.  At the time the petition was filed, petitioners                 
          resided in West Linn, Oregon.  Unless otherwise indicated, all              
          references to petitioner are to Nasser Zamani.                              
               Petitioner was formerly married to Alice Woodworth (Ms.                
          Woodworth).  Petitioner and Ms. Woodworth have three children:              
          (1) Cyrus Zamani, born in 1983; (2) Nathan Zamani, born in 1986;            
          and (3) Lila Zamani, born in 1988.  Petitioner and Ms. Woodworth            
          were divorced on March 3, 1993, pursuant to a divorce decree                
          issued by an Oregon State court.  The divorce decree provides in            
          relevant part:                                                              
               4.   Issues Relating to Children:                                      
                    A.  Custody:  The parties shall have joint                        
               physical custody of the minor children * * *.  The                     
               children are to reside primarily at the mother’s                       
               address for medical and educational purposes.                          
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