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Throughout the years in issue, petitioner provided all financial
support for Apollonia.
On his income tax returns for 1996 and 1997, petitioner
reported gross income in the amounts of $8,047 and $10,446,
respectively. For both years in issue, petitioner claimed a
dependency exemption for Apollonia and head-of-household filing
status. In addition, petitioner claimed the earned income credit
in the amounts of $2,152 and $2,210 for 1996 and 1997,
respectively. In this regard, petitioner attached Schedule EIC
to his return for each year indicating thereon that he was basing
his claim for the credit on Apollonia.
In the notice of deficiency, respondent disallowed the
dependency exemption claimed by petitioner for Apollonia for both
years in issue. Respondent also determined that petitioner was
not entitled to head-of-household filing status; rather,
respondent determined that petitioner's filing status was that of
a single individual. Finally, respondent determined that
petitioner was only entitled to an earned income credit in the
amount of $113 for 1996, and that petitioner was not entitled to
any earned income credit for 1997.
OPINION
We begin with the dependency exemption issue.
A taxpayer is allowed as a deduction an exemption for each
qualifying dependent. See sec. 151(c)(1). A dependent is
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