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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