Marcus T. and Tiffany J. Ringgold - Page 3

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               Respondent determined for 2001 a deficiency in petitioners’            
          Federal income tax of $3,803.  After concessions,1 the sole issue           
          for decision is whether petitioners are entitled to claim a                 
          dependency exemption deduction.                                             
                                     Background                                       
               The stipulation of facts and the exhibits received into                
          evidence are incorporated herein by reference.  At the time the             
          petition in this case was filed, petitioners resided in Richmond,           
          California.                                                                 
               Petitioner Marcus T. Ringgold (petitioner) and Bis-Millah              
          Muhammad (Ms. Muhammad) are the biological parents of NNM.2                 
          Petitioner and Ms. Muhammad have never been married to each                 
          other.  Petitioner and Ms. Muhammad lived apart at all times                
          during 2001.                                                                
               Petitioners jointly filed a Form 1040, U.S. Individual                 
          Income Tax Return, for 2001, claiming for NNM a dependency                  
          exemption deduction.  Respondent issued to petitioners a                    




               1Respondent concedes that petitioners are entitled to claim            
          for 2001:  (1) Charitable contribution deductions of $8,258 on              
          Schedule A, Itemized Deductions, (2) business expense deductions            
          of $2,000 for supplies expenses on Schedule C, Profit or Loss               
          From Business, and (3) a depreciation deduction of $1,136 on                
          Schedule C.  Petitioners concede that they are not entitled to              
          claim Schedule C business expense deductions for rent or lease              
          payments made in 2001.                                                      
               2The Court will refer to the minor child by her initials.              




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