Charles R. Roberts - Page 2

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               Respondent determined a deficiency in petitioner's 1992                
          Federal income tax in the amount of $2,462.                                 
                    The issues for decision are: (1) Whether petitioner's             
          father is his dependent; (2) whether petitioner is entitled to              
          claim an exemption deduction for his father; (3) whether                    
          petitioner is entitled to claim head of household filing status;            
          and (4) whether petitioner is entitled to a deduction for his               
          father's medical expenses.                                                  
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and attached exhibits are incorporated             
          herein by this reference.  Petitioner resided in Leavenworth,               
          Washington, on the date the petition was filed in this case.                
               Petitioner's father, Bert L. Roberts (Mr. Roberts), lived in           
          two nursing homes during the entire taxable year 1992.  Mr.                 
          Roberts received Social Security benefits in the amount of                  
          $12,909 and interest income in the amount of $647 in 1992.  The             
          entire amount of this income was applied against Mr. Roberts'               
          living and medical expenses at the nursing homes.                           
               Petitioner claimed an additional exemption for Mr. Roberts             
          as a dependent and filed as head of household on his 1992 Federal           
          income tax return.  Petitioner also included all of Mr. Roberts'            
          1992 Federal income and Mr. Roberts' claims for medical expense             
          deductions, on petitioner's 1992 Federal income tax return.                 








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