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mother, she does not qualify as a head of household. Sec.
2(b)(1)(A)(ii). Respondent’s determination changing her filing
status from head of household to single is sustained.
3. Earned Income Credit
Subject to various conditions and limitations, an eligible
individual is entitled to an earned income credit. Sec. 32(a).
Petitioner was an eligible individual within the meaning of the
applicable statute. Sec. 32(c)(1)(A)(i) and (ii). Nevertheless,
because of the amount of her income, she is not entitled to an
earned income credit for 1996 unless at least one of her siblings
was a qualifying child with respect to her for that year. Sec.
32(b).
On her 1996 return, petitioner claimed an earned income
credit computed by treating two of her siblings as qualifying
children. Among other requirements, to be treated as a
qualifying child of a taxpayer, the child must be: (1) A son or
daughter of the taxpayer; (2) a descendant of a son or daughter
of the taxpayer; (3) a stepson or stepdaughter of the taxpayer;
or (4) an eligible foster child of the taxpayer. Sec.
32(c)(3)(B)(i). Petitioner’s siblings obviously are not her
children, descendants of her children, or her stepchildren.
Furthermore, they are not her eligible foster children. Although
she generously contributed towards their support, she does not
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