Rodger L. Smith - Page 6

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          food stamps and Pierre's free medical assistance.5  All sources             
          of support must be accounted for in computing the total support             
          provided for Pierre and Sonya in 1992, including amounts                    
          contributed by the individual for his or her own support.  See              
          sec. 1.152-1(a)(2)(ii), Income Tax Regs.  Without proper                    
          substantiation, the court cannot conclude from the record that              
          more than half of Sonya's and Pierre's support was provided by              
          petitioner.  Accordingly, respondent's determination that Sonya             
          and Pierre are not dependents for section 151 purposes is                   
               Petitioner contends that he is entitled to use head of                 
          household filing status for 1992.  Section 1(b) imposes a special           
          tax rate on individuals filing as head of household.  Head of               
          household is defined in section 2(b) as an unmarried individual             
          who maintains his household as the principal place of abode for             
          specific family members for more than one-half the taxable year.            
          To maintain a household as a principal place of abode, the                  
          taxpayer must furnish over half of the household's necessary                
          support over the taxable year.6                                             

               5Welfare or public assistance received by a claimed                    
          dependant is not considered support furnished by the taxpayer.              
          See Gulvin v. Commissioner, 644 F.2d 2 (5th Cir. 1981), affg.               
          T.C. Memo. 1980-111.                                                        
               6Sec. 2(b). DEFINITION OF HEAD OF HOUSEHOLD.--                         
                    (1) In General.--For purposes of this subtitle, an                

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