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received any income from World Medical/Dental during 1991.
Petitioner allegedly purchased various items of equipment from
his father.
Petitioner has failed to prove that he provided in excess of
one-half of the support of his parents during 1991 or that his
parents' income was less than the exemption amount, and, thus,
petitioner cannot claim his parents as dependents.
Respondent determined that petitioner is not entitled to
claim head of household status for the year in issue. Section
2(b) provides:
(1) In general.--For purposes of this subtitle, an
individual shall be considered a head of a household
if, and only if, such individual is not married at the
close of his taxable year, is not a surviving spouse
(as defined in subsection (a)), and either--
(A) * * *
* * * * * * *
(B) maintains a household which constitutes
for such taxable year the principal place of abode
of the father or mother of the taxpayer, if the
taxpayer is entitled to a deduction for the
taxable year for such father or mother under
section 151. [Emphasis added.]
Because petitioner is not entitled to personal exemptions for his
parents under section 151, respondent's determination that
petitioner is not entitled to head of household status will be
sustained.
Accuracy-Related Penalty
Section 6662(a) imposes a penalty in an amount equal to
20 percent of the underpayment of tax attributable to one or more
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