Leroy Walker, Jr. and Carolyn L. Walker - Page 7

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          Erica (Mrs. Walker's daughter) for both 1990 and 1991. During               
          these years, they both were under the age of 19, and petitioners            
          provided over one-half of the support for each of them. Sec.                
          152(a). However, we are not convinced that petitioners are                  
          entitled to dependency exemptions for Monica or any of the                  
          children of Mrs. Walker's stepdaughter. With respect to Monica,             
          the record reveals that she earned $8,000 in 1990, the only year            
          before us in which petitioners claimed a dependency exemption for           
          her. We are not satisfied that petitioners provided over one-half           
          of her support for 1990. Sec. 152(a). With respect to Tremayne,             
          Trovor, and Jessie, the children of Mrs. Walker's stepdaughter,             
          we are not convinced that these children were members of                    
          petitioners' household during 1990 and 1991. The record was held            
          open in order to permit petitioners an opportunity to provide the           
          Court with copies of Tremayne's and Trovor's school records, as             
          petitioners indicated they would, but petitioners failed to                 
          provide such documentation. Accordingly, based on the record                
          before us, we hold that petitioners are entitled to only two of             
          the claimed dependency exemptions for both 1990 and 1991.                   
               4.Child Care Credits                                                   
               Section 21 (a) allows a credit for a "percentage of the                
          employment-related expenses * * * paid by * * * [an] individual             
          during the taxable year" if the individual maintains a household            
          that includes "one or more qualifying individuals". A qualifying            
          individual includes a dependent of the taxpayer who is under the age        




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