- 8 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011