David E. Jackson - Page 4

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            $5,250,2 personal exemptions for himself and Fatimah, a credit                                
            for child and dependent care expenses in the amount of $560, and                              
            an earned income credit of $1,597.                                                            
                  In her notice of deficiency, respondent changed petitioner's                            
            filing status from head of household to single, disallowed the                                
            credit for child and dependent care expenses, disallowed the                                  
            earned income credit, and assessed a negligence penalty.                                      
                  The first issue for decision is whether petitioner qualifies                            
            for head of household filing status.  Petitioner contends that                                
            the room he rented in Ms. Cleckley's apartment constituted a                                  
            household.  Respondent contends that petitioner failed to satisfy                             
            the head of household filing requirements.                                                    
                  We begin by noting that petitioner bears the burden of                                  
            proving that respondent's determination is incorrect.  Rule                                   
            142(a); Welch v. Helvering, 290 U.S. 111 (1933).  We further                                  
            observe that the Court is not bound to accept the unverified,                                 
            undocumented testimony of petitioner.  Hradesky v. Commissioner,                              
            65 T.C. 87, 90 (1975), affd. per curiam 540 F.2d 821 (5th Cir.                                
            1976).  Additionally, a taxpayer is required to substantiate the                              
            amounts claimed as deductions, credits, etc., by maintaining the                              
            records needed to establish such entitlement.  Sec. 6001; sec.                                
            1.6001-1(a), Income Tax Regs.                                                                 



            2           The 1992 standard deduction for head of household                                 
            filing status.                                                                                




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