Craig E. and Debbie A. Brown - Page 14

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          includes one or more qualifying individuals. The amount of the              
          credit is equal to the applicable percentage of the employment-             
          related expenses paid by the individual. Sec. 21(a). The term               
          "qualifying individual" under section 21(b) includes a dependent            
          of the taxpayer under age 13 with respect to whom the taxpayer is           
          entitled to a dependency deduction under section 151(c). The                
          allowable credit, under section 21(b)(2), generally is based upon           
          employment-related expenses that are incurred to enable the                 
          taxpayer to be gainfully employed. The term "employment-related             
          expense" includes expenses for household services and expenses              
          for the care of a qualifying individual. Sec. 21(b)(2)(A).                  
          Employment-related expenses are explained in section 1.44A-                 
          1(c)(2), Income Tax Regs.                                                   
          Sec. 1.44A-1(c). Employment-related expenses--                              
                 (2) Household services. Expenses are considered to be                
               paid for household services if they are paid for the                   
               performance in and about the taxpayer's home of ordinary               
               and usual services necessary to the maintenance of the                 
               household. However, expenses are not considered as paid for            
               household services unless the expenses are attributable in             
               part to the care of the qualifying individual. Thus,                   
               amounts paid for the services of a domestic maid or cook               
               are considered to be expenses paid for household services              
               if a part of those services is provided to the qualifying              
               individual.* * *                                                       
          The term "household services" includes both cleaning and cooking,           
          probably the two services most commonly thought of as household             
          services. Small v. Commissioner, 60 TC 719, 727 (1973), affd.               
          without published opinion (75-2 USMC par. 9512, 10th Cir. October           
          9, 1974, 35,AFTR 2d 75-1383); sec. 1.44A-1(c)(7), Example (3),              




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