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During 1996, 1997, and 1998, petitioner maintained as her
home a household at the South Parsons Avenue address. This home
was owned by petitioner’s grandmother, who contributed to the
cost of maintaining the household. However, petitioner had
greater financial resources than her grandmother, and it was
petitioner who paid most of the cost of maintaining the
household. Further, during these years, petitioner received no
financial assistance from Mr. Corley.
During 1996 and 1997, the household at the South Parsons
Avenue address constituted for more than one-half of each of
those years the principal place of abode of petitioner’s son
Henry. During 1996, 1997, and 1998, the household at the South
Parsons Avenue address constituted for more than one-half of each
of those years the principal place of abode, as a member of such
household, of petitioner’s daughter Ceola and her grandmother
Lillie.
In view of the foregoing, we hold that petitioner’s filing
status for the years in issue was head-of-household.
Respondent’s determination to the contrary is therefore not
sustained.
B. Dependency Exemptions
As relevant herein, a taxpayer is entitled to a dependency
exemption for a son, daughter, or grandmother if more than half
of such individuals’ support is furnished by the taxpayer. See
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