Charles R. Roberts - Page 4

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          nursing home was not documented by any bank records, canceled               
          checks, or other receipts.  More is required by this Court than             
          petitioner's unsubstantiated, unverified, and undocumented                  
          testimony.  Wood v. Commissioner, 338 F.2d 602, 605 (9th Cir.               
          1964), affg. 41 T.C. 593 (1964); Niedringhaus v. Commissioner, 99           
          T.C. 202, 219-220 (1992); Tokarski v. Commissioner, 87 T.C. 74,             
          77 (1986).  Since petitioner did not prove that he paid for more            
          than half of his father's support in 1992, we hold that Mr.                 
          Roberts was not petitioner's dependent in that year.                        
               We now turn to the remaining issues which were contingent              
          upon our holding that Mr. Roberts was not petitioner's dependent            
          in 1992.                                                                    
               The second issue for decision is whether petitioner is                 
          entitled to claim his father as an exemption.  An individual is             
          allowed as a deduction in computing taxable income an additional            
          exemption for each dependent as defined in section 152.  Sec.               
          151(c)(1).  Since we have held that Mr. Roberts is not                      
          petitioner's dependent under section 152, we further hold that              
          petitioner may not claim his father as an exemption because he              
          does not meet the threshold requirements under section 151(c)(1)            
          for the deduction.                                                          
               The third issue for decision is whether petitioner is                  
          entitled to claim head of household filing status for 1992.                 
          "Head of household" is defined, in pertinent part, as an                    
          unmarried individual who maintains a household which constitutes            




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