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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 or
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