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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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Last modified: May 25, 2011