Robert H. Martin - Page 3




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          other court, and this opinion should not be treated as precedent            
          for any other case.                                                         
               Respondent determined a deficiency of $5,485 in petitioner’s           
          Federal income tax for the year 2003.                                       
               The issues for decision are whether petitioner is entitled             
          to:  (1) Dependency exemption deductions for two children under             
          section 151, and (2) a child tax credit under section 24.                   
               Some of the facts were stipulated and are so found.  The               
          stipulation of facts and the annexed exhibits are incorporated              
          herein by reference.  At the time the petition was filed,                   
          petitioner resided at Glen Allen, Virginia.                                 
               Petitioner filed his Federal income tax return for 2003 as a           
          head-of-household under section 2(b)(1) and claimed three                   
          dependency exemption deductions under section 151 and a child tax           
          credit under section 24.  In the notice of deficiency, respondent           
          disallowed the three dependency exemption deductions and the                
          child tax credit.  Respondent further determined that                       
          petitioner’s filing status was single.                                      
               Petitioner was previously married to Olivia L. Martin.  They           
          were divorced in the year 2000.  Olivia L. Martin thereafter                
          married Forrest C. Nuckols.  Petitioner and Mrs. Nuckols had                
          eight children.  For the year at issue, five were adults and                
          three others were dependents.  Petitioner claimed the three                 
          dependents on his Federal income tax return for 2003, and Mrs.              







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