Charles W. Newsom - Page 6




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               Petitioner testified that he and Krissa Williams lived at              
          9908 Independence from January until May 1997.  Petitioner                  
          provided no evidence of his contributions toward maintaining this           
          household.  According to petitioner, Krissa Williams did not live           
          with him during the summer months, and it was not until October             
          1997 that Krissa Williams resumed her residence with petitioner.            
          Petitioner testified that in October 1997 he and Krissa Williams            
          moved into a home at 27 Windsor Drive, which petitioner testified           
          he eventually purchased under a rent-to-buy agreement.  Even if             
          petitioner incurred the entire cost of maintaining his household            
          at 27 Windsor Drive, he maintained this household for only the              
          last 3 months of the year.  We cannot presume that these expenses           
          exceeded one-half of the cost of maintaining Krissa Williams'               
          principal abode for the year.                                               
               We have no doubt that petitioner contributed to the care of            
          Krissa Williams.  In fact respondent did not make an adjustment             
          with respect to petitioner's dependency exemption for Krissa                
          Williams.  The regulations, however, specifically provide that              
          the costs of maintaining a household "do not include the cost of            
          clothing, education, medical treatment, vacations, life                     
          insurance, and transportation."  Sec. 1.7703-1(b)(4), Income Tax            
          Regs.  Without evidence of the cost of maintaining a household or           
          of petitioner's contributions, it is impossible to conclude that            
          petitioner provided more than one-half of the cost of maintaining           





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