- 5 - dependency exemption deductions for Reginald Givens, Jamal Pruitt, Johnnie Payton, and Preather Pruitt. Petitioner also filed as head of household on her 1995, 1996, and 1997 Federal income tax returns and claimed an earned income credit on her 1996 Federal income tax return. Respondent disallowed the dependency exemption deductions because petitioner failed to establish that she was entitled to the exemption for each individual claimed. As a result of the disallowance, respondent further determined that petitioner’s filing status was single, not head of household, disallowed the earned income credit, and imposed accuracy-related penalties. 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 that the following requirements are satisfied: (1) The dependent’s gross income must be less than the amount of the exemption amount for the taxable year in which the deduction is claimed (the gross income requirement); (2) the dependent mustPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011