Oscar Hughes, Jr. - Page 6




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               For purposes of the dependency exemption deduction, support            
          is defined to include “food, shelter, clothing, medical and                 
          dental care, education, and the like.”  Sec. 1.152-1(a)(2)(i),              
          Income Tax Regs.  Respondent points out that the record does not            
          reveal the exact amount of public assistance that Delores                   
          Hamilton received on behalf of the children during the years in             
          issue.  Therefore, according to respondent, it cannot be                    
          determined whether petitioner and Delores Hamilton provided over            
          one half of the children’s support.  We disagree.  Although the             
          record is not as complete as we would like, we are satisfied that           
          the amount of child support petitioner paid, plus the value of              
          the housing that he provided for the children, plus the cost of             
          the children’s medical insurance, plus the incidental expenses he           
          incurred for food, clothing, and entertainment while the children           
          resided at his house, plus whatever support the children received           
          from Delores Hamilton from nonpublic sources, amounted to more              
          than one-half of the children’s total support during the years in           
          issue.                                                                      
               We have considered respondent’s other argument in support of           
          the disallowances of the dependency exemption deductions here in            
          dispute and find the argument to have no application under the              
          circumstances of this case.  Therefore, petitioner is entitled to           
          a dependency exemption deduction for each of his children for               
          each year in issue.                                                         






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