- 4 - for more than one-half the year was his child’s or children’s principal place of abode. Sec. 2(b)(1). Petitioner did not submit any evidence to prove that in either 1997 or 1998 he provided over half the cost of maintaining as his home a household that for more than one-half the year was the principal place of abode of any of his three sons. Petitioner has not shown that he qualifies for head of household filing status for 1997 or 1998. Respondent’s determination is sustained. Issue 2. Dependency Exemptions Petitioner claimed dependency exemption deductions for his three sons for 1997 and 1998. Section 151(c)(1)(B) allows a dependency exemption deduction for each child of the taxpayer so long as the child has not attained age 19 (24 if the child is a student) at the close of the taxable year and more than half of the child’s support for the taxable year was received from the taxpayer. Sec. 152(a). In order for petitioner to establish that he provided more than half of the support for any of his sons, he must show by competent evidence the total support furnished for each of them from all sources during the years at issue. Blanco v. Commissioner, 56 T.C. 512, 514 (1971). Petitioner introduced no evidence of the total support furnished for each of his sons from all sources for either of the years at issue. Moreover, it appears from the judgment of the SuperiorPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011