Karen Ann Keegan - Page 13

                                               - 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                                
            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                            

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  Next

Last modified: May 25, 2011