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Some of the facts were stipulated or otherwise agreed to
and, accordingly, are so found. The Court incorporates by
reference a written stipulation of facts submitted by the parties
at trial. At the time of trial, petitioner was a legal resident
of Virginia.4
Based on the representations of the parties at trial, all
adjustments in the notice of deficiency were settled. However,
petitioner contended at trial that he was entitled to two
dependency exemption deductions for his children. He presented
no evidence to establish his entitlement to such deductions, such
as, for example, the names and ages of the claimed dependents,
whether he or his former spouse had custody of the children, the
total support provided to the claimed dependents from all sources
during the year at issue, and whether the support he provided
constituted more than one-half of the support for each child. In
addition, petitioner did not file a Federal income tax return for
the year at issue.
Section 151(c) allows taxpayers an annual exemption amount
for each “dependent” as defined in section 152. Under section
4At the conclusion of the trial, petitioner was ordered to
file an opening brief. Petitioner submitted an opening brief;
however, the brief was not filed and was returned for copies as
required by Rule 151(d). Respondent was ordered to file an
answering brief, and a brief was submitted to the Court by
respondent. That brief, however, was not filed and was returned
because petitioner’s brief was not filed. Petitioner has not
resubmitted his brief.
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Last modified: November 10, 2007