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Respondent determined a deficiency of $4,658 in petitioner’s
Federal income tax for 2003. After concessions by respondent,
hereafter noted, the sole issue for decision is whether
petitioner, under section 151, is entitled to dependency
exemption deductions for two of his three children from a prior
marriage.
Some of the facts were stipulated, and those facts, with the
annexed exhibits, are so found and are incorporated herein by
reference. At the time the petition was filed, petitioner’s
legal residence was Sunbury, North Carolina.
Petitioner was married in 1989 and, prior to the year at
issue, divorced. Three children were born of this marriage, and,
on his Federal income tax return for the year at issue, he
claimed dependency exemption deductions for the three children as
dependents. Petitioner filed his return as a head-of-household
under section 2(b) and claimed the child tax credit under section
24(a) with respect to each child. In the notice of deficiency,
respondent disallowed the three dependency exemptions and the
child tax credit and changed petitioner’s filing status to
single. At trial, respondent conceded that petitioner was
entitled to head-of-household filing status and the dependency
exemption deduction for one child due to the fact that the child
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