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the principal place of abode of the father or mother of the
taxpayer, if the taxpayer is entitled to a deduction for such
parent under section 151. Sec. 2(b)(1)(B). We hold that
petitioner may not claim head of household status because,
as we have held above, he is not entitled to a deduction for Mr.
Roberts under section 151 and thus does not meet the definition
of head of household.
The final issue for decision is whether petitioner is
entitled to a deduction for his father's medical expenses.
Section 213(a) allows as a deduction the expenses paid during the
taxable year for medical care of the taxpayer's dependent as
defined in section 152. Again, since we have already held that
Mr. Roberts is not petitioner's dependent under section 152, we
further hold that petitioner is not entitled to a deduction for
Mr. Roberts' medical expenses because the requirements of section
213(a) are not met.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011