Octavio and Felicitas Olvera - Page 6

                                          6                                           
          Dependency Exemption Deductions                                             
               As relevant here, section 151 allows a taxpayer to deduct an           
          exemption amount for each dependent, as defined in section 152,             
          whose gross income for the calendar year is less than the                   
          exemption amount.  The term "dependent" is defined to include a             
          sister or mother of the taxpayer, over half of whose support for            
          the calendar year is received from the taxpayer.                            
               Respondent contends that petitioners have not established              
          that they provided over one-half of the support for either                  
          petitioner's mother or his sister in 1994.  Thus, respondent                
          argues these individuals were not petitioners' dependents under             
          section 152 in 1994.                                                        
               Although we sympathize with petitioners and acknowledge that           
          they clearly provided some support for petitioner's mother and              
          sister, we cannot find on the basis of the record that they                 
          provided over half of the support for either.  We found                     
          petitioner to be a credible witness.  Petitioner testified that,            
          in addition to $2,400 wired to various relatives in Mexico in               
          1994, he took somewhere between $2,000 and $2,500 in cash with              
          him on his trip to Mexico, and that he gave cash to cousins to              
          take to Mexico as well.  However, some of this money must have              
          been used to support Mrs. Olvera and petitioners' daughters, as             
          they had no other identified means of support.  Petitioner                  
          testified that Mrs. Olvera's parents were unwilling to help                 






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