- 4 -
respondent for the years in issue, none of which are petitioner's
address. Isatu received wages in the amounts of $1,749 and
$2,871 in 1995 and 1996, respectively.
On his 1996 Federal income tax return, petitioner claimed
five dependency exemption deductions which included Isatu,
Damonta, Briana, Randy Thompson (Randy), who is also a child of
Ms. Thompson, and his nephew, Mohamed Koroma (Mohamed).
Petitioner reported all five claimed dependents as his children
who resided with him for all 12 months of the 1996 calendar year.
Petitioner claimed head-of-household filing status and a
dependent care credit in the amount of $960. Petitioner's
nephew, Mohamed, left Africa in 1996 to reside with petitioner in
the United States. Mohamed was employed in 1996.
The notice of deficiency disallowed (1) the claimed
dependency exemption deductions, (2) the head-of-household filing
status, and (3) the claimed dependent care credits. Respondent
adjusted petitioner's filing status to single for both years in
issue.
Discussion
We begin by noting that, as a general rule, the
Commissioner's determinations are presumed correct. See Rule
142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Deductions
are a matter of legislative grace, and the taxpayer bears the
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011