- 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 morePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011