Tiffany Paramore - Page 6




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          Regs.  Support also includes public assistance, such as welfare             
          and food stamps, received by the individual.  These items are               
          calculated as part of the total amount of support received by the           
          individual and are not attributed to the taxpayer.  See Gulvin v.           
          Commissioner, 644 F.2d 2, 3 (5th Cir. 1981), affg. T.C. Memo.               
          1980-111; Smith v. Commissioner, supra.                                     
               Petitioner failed to establish that she provided more than             
          one-half of Simeon’s support.  We are unsure as to the total                
          amount of support Simeon received from all sources.  The record             
          is also silent as to the amount of support Simeon received from             
          petitioner.  Therefore, we sustain respondent’s determination.              
               2. Filing Status                                                       
               In order to qualify for head-of-household filing status, a             
          taxpayer must satisfy the requirements of section 2(b).  Pursuant           
          to that section, and as relevant herein, an individual qualifies            
          as a head of household if the individual is not married at the              
          close of the taxable year and maintains as her home a household             
          that constitutes for more than one-half of the taxable year, the            
          principal place of abode of a son or daughter of the taxpayer.              
          Sec. 2(b)(1)(A)(i).  A taxpayer is considered as maintaining a              
          household only if more than half of the cost of maintaining the             
          household during the taxable year is furnished by the taxpayer.             
               Petitioner was not married at the close of 1998.  Simeon               
          lived with petitioner for the entire year at issue.  However,               






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