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Pursuant to section 7463(b), the decision to be entered is not
reviewable by any other court, and this opinion shall not be
treated as precedent for any other case.
Respondent determined a deficiency of $6,211.18 in Federal
income tax for petitioner’s 2005 tax year.
The issues for decision are whether, for the year 2005,
petitioner is entitled to (1) dependency exemption deductions for
two children under section 151(c); (2) head of household filing
status under section 2(b)(1); (3) the earned income credit under
section 32(a); (4) the child care credit under section 21(a)(1);
and (5) the additional child tax credit under section 24(a).
Some of the facts were stipulated. Those facts, with the
exhibits annexed thereto, are so found and are made part hereof.
Petitioner’s legal residence at the time the petition was filed
was Atlanta, Georgia. For reasons of privacy, the two children
claimed as dependents on petitioner’s 2005 Federal income tax
return are not identified by name and are referred to simply as
the “children”.
1(...continued)
Commissioner only if the taxpayer has complied with all
requirements as to substantiation and has maintained the
necessary books and records with respect to the factual issues.
The burden does not shift to respondent in this case because
petitioner maintained no books and records or any other factual
evidence to establish his entitlement to the principal issue,
entitlement to dependency exemption deductions.
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Last modified: March 27, 2008