Rutha M. Corley - Page 8




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          principal place of abode, as a member of such household, of                 
          either (1) a son or a daughter or (2) any other person who is a             
          dependent of the taxpayer, if the taxpayer is entitled to a                 
          dependency exemption for the taxable year for such person under             
          section 151.  See sec. 2(b).                                                
               The cost of maintaining a household is the sum of the                  
          expenses incurred for the mutual benefit of the occupants of the            
          household by reason of its operation as the principal place of              
          abode of such occupants for the taxable year.  See sec. 1.2-2(d),           
          Income Tax Regs.  Such expenses include property taxes, mortgage            
          interest, rent, utility charges, upkeep and repairs, property               
          insurance, and food consumed on the premises; however, such                 
          expenses do not include the cost of clothing, education, medical            
          treatment, vacations, life insurance, and transportation.  See              
          id.                                                                         
               During virtually all of 1995, petitioner maintained as her             
          home a household at the West Euclid Avenue address that                     
          constituted for more than one-half of that year the principal               
          place of abode of her children Henry and Ceola.  During this                
          period, petitioner received no financial assistance from Mr.                
          Corley.  Although petitioner received some financial assistance             
          from her grandmother, petitioner was the person principally                 
          responsible for maintaining the household at the West Euclid                
          Avenue address.                                                             






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