Larry Jackson Beard and Gloria Dean Beard - Page 11

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          than one-half of Jacqueline's support during 1992.  Petitioners             
          assert that they are entitled to the deduction.                             
               Section 151(c)(1) generally allows as a deduction an                   
          exemption for each dependent of a taxpayer as defined in section            
          152.  Section 152(a) provides, in general, that the term                    
          "dependent" means certain individuals over half of whose support            
          was received from the taxpayer during the taxable year in which             
          such individuals are claimed as dependents.  Eligible individuals           
          who may be claimed as dependents include, among others, a son or            
          daughter of the taxpayer.  Sec. 152(a)(1).  Section 151(c)                  
          further provides that the claimed dependent's gross income for              
          the taxable year must be less than the exemption amount, or if              
          the claimed dependent is a child of the taxpayer claiming the               
          exemption, the child must not have attained the age of 19 at the            
          close of the calendar year or must be a student who has not                 
          attained the age of 24 at the close of the calendar year.  Sec.             
          151(c)(1)(A) and (B).                                                       
               During 1992, Jacqueline had attained the age of 20 at the              
          close of the year but was a student.  She maintained a part-time            
          job during 1992.  Based on Jacqueline's 1992 return, her gross              
          income from wages was $5,182.93.                                            
               Petitioner did not present competent evidence to establish             
          the total support provided to Jacqueline during 1992, and that,             
          of the total support provided, more than one-half of the amount             
          was provided by petitioner.  See Blanco v. Commissioner, 56 T.C.            



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