- 4 - Petitioner listed his filing status as a head of household on his Federal income tax return for each year in issue. He did not elect to itemize deductions for either year. Relevant for our purposes, on each return he claimed a dependency exemption deduction for each of his children and an earned income credit. Petitioner computed the earned income credit claimed on each return by treating two of his children as “qualifying” children. Delores Hamilton did not file a Federal income tax return for any year in issue. For each year she signed a Form 8332, Release of Claim to Exemption for Child of Divorced or Separated Parents. In the notice of deficiency for each year, respondent changed petitioner’s filing status from head of household to single and reduced the standard deduction accordingly. Respondent also disallowed all of the claimed dependency exemption deductions and the earned income credit. No explanations for the adjustments were included in the notices of deficiency. OPINION I. Dependency Exemption Deductions Generally, section 151(c) allows a taxpayer a dependency exemption deduction for each dependent as defined in section 152. The term "dependent" includes certain individuals, such as a son or daughter, "over half of whose support, for the calendar yearPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011