- 5 - 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,Page: Previous 1 2 3 4 5 6 7 8 Next
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