Thaddeus D. Hollingsworth - Page 5




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          filing status was single, not head of household, and also                   
          disallowed the earned income credit.                                        
          Dependency Exemption                                                        
               Section 151(c) allows a taxpayer to deduct an annual                   
          exemption amount for each dependent of the taxpayer.  A                     
          “dependent” is defined in section 152(a) as an individual “over             
          half of whose support, for the calendar year in which the taxable           
          year of the taxpayer begins, was received from the taxpayer (or             
          is treated under subsection (c) or (e) as received from the                 
          taxpayer)”.  In order to prevail, petitioner must show by                   
          competent evidence: (1) The total support provided for each                 
          child, and (2) that he provided more than half of such total                
          support.  The amount of total support may be reasonably inferred            
          from competent evidence.  See Stafford v. Commissioner, 46 T.C.             
          515, 518 (1966).  However, where the amount of total support of a           
          child during the taxable year is not shown, and cannot be                   
          reasonably inferred from competent evidence, then it is not                 
          possible to conclude that the taxpayer has contributed more than            
          one-half.  See Blanco v. Commissioner, 56 T.C. 512, 515 (1971);             
          Fitzner v. Commissioner, 31 T.C. 1252, 1255 (1959).                         
               Although we find petitioner’s testimony credible as to the             
          amount he contributed to the children’s support, the record based           
          solely on his contributions is incomplete.  Petitioner was unable           
          to reconstruct the dollar amount of the total support for the               





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