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The Internal Revenue Service (IRS) did not challenge the
dependency exemption on Mr. Chamberlain’s individual and joint
Federal income tax returns for the taxable years 1996 through
2002, despite Mr. Chamberlain’s failure to comply with the
written declaration requirement.
In their joint Federal income tax return for the taxable
year 2003, petitioners claimed a dependency exemption and a child
tax credit for one child; once again affixing a Post-itŪ note to
their joint return referencing Mrs. Norris’s 1995 Form 8332.
However, Mrs. Norris and her current husband claimed both
children as dependents on their 2003 joint Federal income tax
return. To protect the Government from the whipsaw effect of
this double claim, respondent determined that petitioners were
not entitled to claim the dependency exemption deduction under
section 151.
In March 2005, respondent issued a $1,047 notice of
deficiency to petitioners for the dependency exemption and child
tax credit claimed for the taxable year 2003. Petitioners timely
petitioned this Court for a redetermination and later amended
their petition. In the amended petition, petitioners addressed
Mrs. Norris’s 1995 Form 8332 declaring that “[The] IRS honored
this Form until 2003”.
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Last modified: November 10, 2007