Michael Scott Snelgrove, Sr. - Page 7




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          Petitioner has not satisfied these requirements, and,                       
          accordingly, respondent is sustained in disallowing petitioner              
          the dependency exemption deductions for his two children.                   
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   


          Decision will be entered                                                    
          under Rule 155.                                                             
































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