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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 for
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