Tiffany Paramore - Page 7




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          petitioner failed to demonstrate that she furnished more than               
          half of the cost of maintaining the requisite household for                 
          Simeon.  Our conclusion is based on the analysis that parallels             
          our previous analysis regarding the dependency exemption issue.             
          We hold that petitioner does not qualify as a head of household             
          for 1998.                                                                   
               3. Earned Income Credit                                                
               On her 1998 Federal income tax return, petitioner claimed an           
          earned income credit based on Simeon as a qualifying child.  In             
          the case of an eligible individual, section 32(a) allows an                 
          earned income credit against the individual’s income tax                    
          liability.  As relevant herein, an “eligible individual” is                 
          defined as an individual who has a “qualifying child” for the               
          taxable year.  Sec. 32(c)(1)(A).                                            
               The record reflects that Simeon is a “qualifying child”                
          pursuant to the requirements set forth in section 32(c)(3)(A)(i             
          through iv).  In this regard, Simeon satisfies the relationship             
          test, see sec. 32(c)(3)(A)(i), (B)(i)(I), the residency test, see           
          sec. 32(c)(3)(A)(ii), and the age test, see sec.                            
          32(c)(3)(A)(iii), (C)(i).  Finally, Simeon is a child with                  
          respect to whom petitioner satisfied the identification                     
          requirement under section 32(c)(3)(C)(A)(iv), (D)(i) by setting             
          forth his name, age, and applicable taxpayer identification                 
          number on Schedule EIC, Earned Income Credit.                               






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