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2003, pursuant to sections 1511 and 24, respectively. We hold
that petitioners are not entitled to either the dependency
exemption or the child tax credit, because petitioners failed to
attach a valid Form 8332, Release of Claim to Exemption for Child
of Divorced or Separated Parents, to their joint Federal income
tax return for the taxable year 2003 as required by the Internal
Revenue Code and its corresponding regulations.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the accompanying exhibits are
incorporated herein by this reference. Petitioners are husband
and wife and resided in Roanoke, Virginia, at the time their
petition was filed.
Mr. Chamberlain and Suzanna D. Norris divorced in February
1993. Mr. Chamberlain and Mrs. Norris had two children by their
marriage. The terms of the divorce decree granted custody of
both children to Mrs. Norris, and both children resided with Mrs.
Norris at all times from 1993 through 2003.
After the divorce, Mr. Chamberlain and Mrs. Norris came to
an understanding, wherein each would claim a dependency exemption
for one of their two children. Accordingly, Mrs. Norris executed
separate Forms 8332 for the taxable years 1993 and 1994. Mr.
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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