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Dependency Exemption Deduction
Petitioner argues that he is entitled to claim a dependency
exemption deduction with respect to Dina. Sections 151 and 152
provide that a taxpayer is entitled to deduct an exemption for a
minor dependent if the taxpayer provides more than half of the
support for the minor dependent. A daughter of a taxpayer is
included in the definition of a dependent. Sec. 152(a)(1). The
issue with regard to the dependency exemption deduction claimed
by petitioner is whether petitioner established that he provided
more than half of the support for Dina.
Petitioner claims that he paid approximately $600 per month
for food, clothing, etc., and $500 per month for housing for the
support of Ms. Duverger, Dina, the other child, and himself,
totaling $1,100 per month. Petitioner has no records
establishing these amounts. We pointed out at trial that the
total support he allegedly paid per year would have been $13,200,
approximately $5,000 more than his reported taxable income. He,
therefore, either understated his taxable income or overstated
the amount that he allegedly paid for support. Moreover,
petitioner had no idea what the total cost for support was or
what the total cost was for the support of Dina. Given that Ms.
Duverger had a taxable income of more than twice the amount
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Last modified: May 25, 2011