Neil J. Norman - Page 4




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          taxable year 2003, petitioner was current on his child support              
          obligations.                                                                
               Petitioner filed timely Form 1040A, U.S. Individual Income             
          Tax Return, for 2003, on which he claimed dependency exemptions             
          for both of his daughters, and a child tax credit for JN2.                  
          Petitioner attached to his 2003 Federal income tax return select            
          nonsequential pages of the Judgment and Decree of Divorce that              
          reflected that petitioner was entitled to the dependency                    
          exemptions for JN1 and JN2 if petitioner was current on his child           
          support obligations.  The attachment was not signed by                      
          petitioner’s former spouse.  Petitioner’s former spouse also                
          claimed dependency exemptions for JN1 and JN2 on her 2003 Federal           
          income tax return.                                                          
               The notice of deficiency was sent to petitioner on                     
          August 22, 2005, and showed a deficiency of $2,125 for taxable              
          year 2003.  In the notice of deficiency, respondent disallowed              
          the two dependency exemptions and the child tax credit.  In                 
          response, petitioner submitted to respondent Form 8332, Release             
          of Claim to Exemption for Child of Divorced or Separated Parents,           
          dated October 20, 2005.  Petitioner’s former spouse signed                  
          Part I, Release of Claim to Exemption for Current Year, and                 
          indicated the release was effective for taxable year 2003.                  
          Neither this nor any other Form 8332 was attached to petitioner’s           
          2003 Federal income tax return.  Petitioner filed a timely                  







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