- 18 -
care to her three resident grandchildren". The Schedule C shows
a business expense of $2,416 for food and $212 for "fast food".
The record does not indicate how, if at all, these expenses
figure in any of petitioner's support computations.
Eventually, on December 18, 1996, petitioner submitted a
more detailed "Dependency Support Worksheet" with some additional
and some different figures (still without substantiation) from
those originally submitted in the letter of October 30, 1996.
The case was settled 2 days later.
We find in this case that respondents's position denying
deductions for dependency exemptions was reasonable in fact and
in law.
Head of Household Filing Status
Individuals who qualify as heads of households have special
tax rates applied to their taxable income. See sec. 1(b). As
relevant here, in order to qualify for head of household
treatment, a taxpayer must maintain a household which for more
than one-half of the taxable year is the principal place of abode
of a dependent of the taxpayer. See sec. 2(b)(1)(A)(ii).
We have found that respondent's position that petitioner had
no dependents for the taxable year was reasonable. Because
petitioner would be eligible for head of household filing status
only if, among other requirements, his niece and nephew were his
dependents, it follows that respondent's position that petitioner
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011