- 6 - his brother and mother being his dependents. Section 2(b)(1)(A) and (B), in pertinent part, defines a head of household as an unmarried individual who maintains as his home a household which constitutes for more than one-half of such taxable year the principal place of abode, as a member of such household, of–- ****** * (ii) any * * * dependent of the taxpayer, if the taxpayer is entitled to a deduction for the taxable year for such person under section 151 * * * (B) maintains a household which constitutes for such taxable year the principal place of abode of the father or mother of the taxpayer, if the taxpayer is entitled to a deduction for the taxable year for such father or mother under section 151. Ignoring the question whether petitioner even maintained a residence for his brother and/or his mother, as we have already discussed, petitioner is not entitled to claim either as a dependent, and we sustain respondent’s determination that petitioner is not entitled to head of household filing status for the years in issue. B. Schedule C Losses Section 162(a) allows a deduction for ordinary and necessary expenses paid or incurred in carrying on a trade or business. Generally, under section 183(a) and (b) an individual is not allowed deductions attributable to an activity “not engaged in for profit” except to the extent of gross income generated by the activity. Section 183(c) defines an activity “not engaged in forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011