def test_failing_examples(self, mock):
paths = mock()
for path in paths:
with open(path) as f:
data = json.loads(f.read())
cite = find_tax_court_citation(data["html"])
self.assertFalse(cite)
print("Success ✓")
def test_working_examples(self, mock):
paths = mock()
for path in paths:
with open(path) as f:
data = json.loads(f.read())
cite = find_tax_court_citation(data["html"])
self.assertEqual(cite.base_citation(), data["cite"])
print("Success ✓")
print(data["notes"])
def test_tax_court_citation_extractor(self):
"""Find Tax Court Citations """
test_pairs = (
(
""" 1 UNITED STATES TAX COURT REPORT (2018)
UNITED STATES TAX COURT
BENTLEY COURT II LIMITED PARTNERSHIP, B.F. BENTLEY, INC., TAX
MATTERS PARTNER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5393-04. Filed May 31, 2006.
Nancy Ortmeyer Kuhn, for petitioner.
""",
"1 T.C. 2018",
),
(
""" T.C. Memo. 2003-150
UNITED STATES TAX COURT
RIVER CITY RANCHES #1 LTD., LEON SHEPARD,
TAX MATTERS PARTNER,
RIVER CITY RANCHES #2 LTD., LEON SHEPARD,
TAX MATTERS PARTNER,
RIVER CITY RANCHES #3 LTD., LEON SHEPARD,
TAX MATTERS PARTNER,
""",
"2003 T.C. Memo. 150",
),
(
""" T.C. Summary Opinion 2003-150
UNITED STATES TAX COURT
RIVER CITY RANCHES #1 LTD., LEON SHEPARD,
TAX MATTERS PARTNER,
RIVER CITY RANCHES #2 LTD., LEON SHEPARD,
TAX MATTERS PARTNER,
RIVER CITY RANCHES #3 LTD., LEON SHEPARD,
TAX MATTERS PARTNER,
""",
"2003 T.C. Summary Opinion 150",
),
(
r"""
MICHAEL KEITH SHENK, PETITIONER v. COMMISSIONER
OF INTERNAL REVENUE, RESPONDENT
Docket No. 5706–12. Filed May 6, 2013.
P was divorced from his wife, and their 2003 ‘‘Judgment of
Absolute Divorce’’ provided that his ex-wife would have pri-
mary residential custody of their three minor children. The
judgment provided that the dependency exemption deductions
for the three children would be divided between the two ex-
spouses according to various conditions but did not provide
that the ex-wife must execute in P’s favor a Form 8332,
‘‘Release of Claim to Exemption for Child of Divorced or Sepa-
rated Parents’’. The children resided with P’s ex-wife for more
than half of 2009, and P’s ex-wife did not execute in P’s favor
any Form 8332 or equivalent document for any year. For 2009
P timely filed a Federal income tax return on which he
claimed dependency exemption deductions and the child tax
credit for two of the children, consistent with his under-
standing of the terms of the judgment, but he did not attach
any Form 8332 to his return. He also claimed head-of-house-
hold filing status. His ex-wife, the custodial parent, timely
filed a Federal income tax return for 2009 on which she also
200
VerDate Nov 24 2008 10:59 Jul 11, 2014 Jkt 372897 PO 20012 Frm 00001 Fmt 3857 Sfmt 3857 V:\FILES\BOUND VOL. WITHOUT CROP MARKS\B.V.140\SHENK JAMIE
(200) SHENK v. COMMISSIONER 201
claimed two dependency exemption deductions, so that one
child was claimed on both parents’ returns. R allowed to P the
dependency exemption deduction for one of the children but
disallowed his claim for the dependency exemption deduction
for the child who had also been claimed by the custodial
parent. At trial P contended he is entitled to a dependency
exemption deduction for all three children. Held: Since the
custodial parent did not execute, and P could not and did not
attach to his return, any Form 8332 or equivalent release, P
is not entitled under I.R.C. sec. 152(e)(2)(A) to claim the
dependency exemption deduction or the child tax credit. Held,
further, where both the custodial parent and the noncustodial
parent have claimed for the same year a dependency exemp-
tion deduction for the same child, a declaration signed by the
custodial parent after the period of limitations for assess-
ments has expired as to the custodial parent could not qualify
under I.R.C. sec. 152(e)(2)(A), and therefore there is no reason
to grant P’s request to leave the record open so that he may
obtain and proffer such a declaration. Held, further, P is not
entitled to head-of-household filing status under I.R.C. sec.
2(b)(1) nor to the child tax credit under I.R.C. sec. 24.
Michael Keith Shenk, for himself.
Shari Salu, for respondent.
GUSTAFSON, Judge: The Internal Revenue Service (IRS)
determined a deficiency of $3,136 in the 2009 Federal income
tax of petitioner Michael Keith Shenk. Mr. Shenk petitioned
this Court, pursuant to section 6213(a), 1 for redetermination
of the deficiency. After Mr. Shenk’s concession that he
received but did not report $254 in dividend income, the
issue for decision is whether Mr. Shenk is entitled to a
dependency exemption deduction for one of his children
under section 151(c), a child tax credit for that child under
section 24(a), and head-of-household filing status under sec-
tion 2(b)(1). On these issues, we hold for the IRS.
FINDINGS OF FACT
The judgment of divorce
Mr. Shenk was married to Julie Phillips, and they have
three minor children—M.S., W.S., and L.S. They divorced in
2003. The family court’s ‘‘Judgment of Absolute Divorce’’ pro-
1 Unless otherwise indicated, all citations of sections refer to the Internal
Revenue Code (26 U.S.C.) in effect for the tax year at issue, and all cita-
tions of Rules refer to the Tax Court Rules of Practice and Procedure.
VerDate Nov 24 2008 10:59 Jul 11, 2014 Jkt 372897 PO 20012 Frm 00002 Fmt 3857 Sfmt 3857 V:\FILES\BOUND VOL. WITHOUT CROP MARKS\B.V.140\SHENK JAMIE
202 140 UNITED STATES TAX COURT REPORTS (200)
vided: that Ms. Phillips was ‘‘awarded primary residential
custody’’ of the parties’ three children; and that Mr. Shenk
would be liable for child support payments; but that, as to
dependency exemptions—""",
"140 T.C. 200",
),
)
for q, a in test_pairs:
cite = find_tax_court_citation(q)
cite_string = " ".join(
[str(cite.volume), cite.reporter,
str(cite.page)])
self.assertEqual(cite_string, a, msg="Success")
print("✓")