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Both Sonya and Pierre Tolbert received some form of public
assistance while living in Ms. Wiggins' home. Sonya Tolbert
received $110 each month in food stamps and Pierre Tolbert's
medical expenses were paid by the State of Georgia Department of
Medical Assistance.
Petitioner filed as head of household for the taxable year
1992 and claimed dependency exemptions for both Sonya and Pierre
Tolbert. Petitioner also claimed the earned income credit in
1992 for Sonya and Pierre Tolbert in the amount of $1,261.
Respondent disallowed petitioner's claim for dependency
exemptions on the grounds that he did not provide over one half
of Sonya's and Pierre's support during 1992. Respondent also
denied petitioner's claim for the earned income credit and his
head of household filing status.
Discussion
Respondent's determinations are presumed correct, and
petitioner has the burden of proving them erroneous. Rule
142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Taxpayers
must maintain adequate records to substantiate the amount of any
deductions or credits claimed. Sec. 6001; sec. 1.6001-1(a),
Income Tax Regs.
The first issue we address is whether petitioner is entitled
to claim dependency exemption deductions for Sonya and Pierre
Tolbert. Section 151(c)(1) allows a taxpayer to claim an
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