Leona Payton - Page 9




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          debt by “paying them back, yearly, yearly, yearly***”  Although             
          we sympathize with petitioner and acknowledge that she clearly              
          provided some support to each individual claimed, we cannot find,           
          on the basis of the record, that petitioner provided over half of           
          the total support for most of the claimed dependents as required            
          by section 152.  Because petitioner failed to establish the total           
          amount of support from all sources, we are unable to conclude               
          that petitioner provided more than one-half of the total support            
          for Racquelle, Rafael, Jamal, Reginald, and Preather.  Therefore,           
          we hold that petitioner is not entitled to section 151 dependency           
          exemption deductions for the taxable years 1995, 1996, and 1997             
          as to Racquelle, Rafael, Jamal, Reginald, and Preather.                     
               However, as to Johnnie, we believe petitioner’s testimony              
          regarding Johnnie’s inability to contribute to his own support              
          during a time when he was trying to “beat a habit”.  We find that           
          petitioner did contribute more than half of his support, and,               
          therefore, petitioner is entitled to claim section 151 dependency           
          exemption deductions for Johnnie in 1995, 1996, and 1997.                   
          Head of Household Status                                                    
               According to the relevant part of section 2(b), an                     
          individual shall be considered a head of household if such                  
          individual (1) is not married at the close of the taxable year              
          and (2) maintains as her home a household which constitutes for             
          more than one-half of the taxable year the principal place of               





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