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Upon the basis of the record, we find that petitioner
satisfied the head of household filing requirements of section
2(b). We therefore hold that petitioner is entitled to file as
head of household for the 1994 tax year.
4. Dependency Exemption Deductions
Petitioner claimed a dependency exemption deduction on his
1994 Federal income tax return.
Deductions are a matter of legislative grace, and the
taxpayer bears the burden of proving that he is entitled to any
deductions claimed. INDOPCO, Inc. v. Commissioner, 503 U.S. 79,
84 (1992).
Section 151 allows a taxpayer to deduct an exemption amount
for each dependent as defined in section 152. The term
"dependent" includes a taxpayer's son over half of whose support
for the calendar year is received from the taxpayer. Sec.
152(a)(1).
Petitioner testified that his son lived with him for the
entire 1994 tax year, and it is clear from the record that
petitioner met the support requirement of section 152 by
providing over half of his son's support for the 1994 tax year.
We find that petitioner satisfied the requirements of
section 151, and, therefore, hold that petitioner is entitled to
a dependency exemption deduction for his son for the 1994 tax
year.
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