Memorandum Findings of Fact and Opinion
JOHNSTON, Commissioner:
Respondent determined a deficiency of $660.00 in petitioners' Federal income tax for the year 1967. The question presented is whether petitioners are entitled to claim five dependency exemptions for the children of petitioner-husband by a former marriage who were in the legal custody of their mother during the calendar year 1967 under sections 151 and 152, Internal Revenue Code of 1954.
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