§97

His supplemental brief also includes the assertion that "petitioner did not acquire amortizable assets as defined by section 97(d) [sic] in conjunction with the merger/reorganization transaction at issue." Although respondent consistently refers to the transaction in which petitioner acquired the assets of the transferred business as a "merger/reorganization", it was neither.

His supplemental brief also includes the assertion that "petitioner did not acquire amortizable assets as defined by section 97(d) [sic] in conjunction with the merger/reorganization transaction at issue." Although respondent consistently refers to the transaction in which petitioner acquired the assets of the transferred business as a "merger/reorganization", it was neither.

97-29-1 (1999); see also Davis v. Davis, 643 So. 2d 931 (Miss. 1994); Sullivan v. Stringer, 736 So. 2d 514 (Miss. Ct. App. 1999). Petitioner does not claim a dependency exemption for the mother, and correctly so. See Turnipseed v. Commissioner, 27 T.C. 758 (1957). However, petitioner asserts that his living arrangement with the children does n