Craig V. Adams - Page 12

                                       - 12 -                                         
          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           



Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  Next

Last modified: May 25, 2011