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2 Mrs. Cotton reported Shaquita Douglas as her foster
child.
3 Mrs. Cotton reported Starlesha Cotton as her niece.
4 Mrs. Cotton reported Kevin Cotton as her nephew.
Mrs. Cotton claimed earned credits in the amounts of $640
and $1,152 in 1994 and 1996, respectively. Mr. Cotton claimed
the following deductions:
1994 1995 1996
Medical expenses $10,001 --- $3,980
Tax preparation 200 200 225
Unreimbursed employee expenses 5,700 7,000 4,205
Real estate tax --- --- 2,804
Respondent disallowed the dependency exemption deductions
(except for Samuel Douglas in 1994) claimed by petitioners
because petitioners did not establish that they provided more
than one-half of the support for any of the claimed dependents.
Respondent disallowed Mrs. Cotton’s earned income credits, on two
theories: First, she did not establish that she had a qualifying
child under section 32(a); second, she did not file a joint
return with Mr. Cotton. Respondent disallowed the deductions for
medical expenses, tax preparation fees, unreimbursed employee
expenses, and real property taxes because Mr. Cotton did not
establish that he paid these amounts for the reasons claimed.
Since the disallowed deductions for 1994 and 1995 reduced
Mr. Cotton’s total itemized deductions to amounts less than the
standard deduction, respondent disallowed the other itemized
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