Robert Cotton, Jr. - Page 8




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          deductions and allowed Mr. Cotton the standard deduction for 1994           
          and 1995.  Respondent disallowed the standard deduction for Mrs.            
          Cotton in 1996 because Mr. Cotton itemized deductions on his                
          separate return.                                                            
                                       OPINION                                        
               Deductions are a matter of legislative grace, and taxpayers            
          must comply with the specific requirements for any deduction                
          claimed.  See INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84                
          (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440                
          (1934).  Taxpayers must maintain adequate records to substantiate           
          the amount of credits and deductions claimed.  See sec. 6001;               
          sec. 1.6001-1(a), Income Tax Regs.                                          
          1.   Dependency Exemption Deductions                                        
               A taxpayer is permitted to claim a deduction for personal              
          exemptions.  See sec. 151(a).  A taxpayer may claim an exemption            
          for dependents.  See sec. 151(c)(1).  A taxpayer’s son, sister,             
          brother, sister-in-law, brother-in-law, niece, and nephew qualify           
          as dependents so long as the taxpayer provided more than half of            
          the support to each dependent.  See sec. 152(a)(1), (3), (6),               
          (8); sec. 1.152-1(a)(1), Income Tax Regs.  Further, a taxpayer              
          may claim a dependency exemption deduction for an unrelated                 
          individual who has as his principal place of abode the home of              
          the taxpayer, so long as the taxpayer provided more than one-half           
          of the support to the unrelated individual.  See sec. 152(a)(9).            






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