Rutha M. Corley - Page 11




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          demonstrates that petitioner provided more than half of Henry’s             
          support in 1997.5                                                           
               Insofar as Lillie Lucas, petitioner’s grandmother, is                  
          concerned, the record demonstrates that she received Social                 
          Security benefits for the years in issue and expended some                  
          portion of those benefits for her own support.6  However,                   
          petitioner had greater financial resources than her grandmother,            
          and the record demonstrates that petitioner expended her total              
          income to support the family and to maintain the West Euclid                
          Avenue residence (in 1995) and the South Parsons Avenue residence           
          (in 1996 through 1998).  Overall, we are satisfied that the                 
          record establishes that petitioner paid more than half of her               
          grandmother’s support for the years in issue.                               
               In view of the foregoing, we hold that petitioner is                   
          entitled to dependency exemptions for Ceola, Henry, and her                 
          grandmother as claimed by her on her tax returns for the years in           
          issue.  Respondent’s determination to the contrary is therefore             
          not sustained.                                                              
               C. Earned Income Credit                                                
               In the case of an eligible individual, section 32(a) allows            
          an earned income credit.  As relevant herein, the term “eligible            

               5 It should be recalled that petitioner did not claim a                
          dependency exemption for Henry for 1998.                                    
               6  Ms. Lucas also expended some portion of her Social                  
          Security benefits to help support petitioner and her children.              





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