- 13 - costs" were estimated. Petitioner failed to provide any detailed testimony concerning these claimed expenses and offered no written substantiation. We, therefore, have no basis to make an estimate. Petitioner has failed to meet her burden of proving entitlement to these claimed expenses. Rule 142(a). Accordingly, we sustain respondent's determination to that extent. 3. Dependency Exemption and Filing Status for 1994 and 1995 (a) Dependency Section 151(c) allows an exemption amount for each dependent: (1) Whose gross income for the taxable year is less than the exemption amount, or (2) who is a child of the taxpayer and is a student who has not attained the age of 24 at the close of such calendar year. Sec. 151(c)(1)(A) and (B)(ii). Dependents are generally defined as individuals who receive over half of their support from a taxpayer in the calendar year in which that taxpayer's taxable year begins. Sec. 152(a). For purposes of determining whether or not an individual received over one-half of his or her support from the taxpayer during a given calendar year, there shall be taken into account the amount of support received from the taxpayer as compared to the entire amount of support which the individual received from all sources. Sec. 1.152-1(a)(2)(i), Income Tax Regs. Support includes amounts which an individual has contributed to his orPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011