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should not be cited as authority.
Respondent determined a deficiency of $3,726 in petitioner's
1997 Federal income tax and a section 6651(a)(1) addition to tax
of $108.15. The issues for decision are: (1) Whether petitioner
is entitled to claim dependency exemption deductions for his
three nephews; (2) whether petitioner qualifies as a head of
household; (3) whether petitioner is entitled to an earned income
credit; and (4) whether petitioner is liable for the section
6651(a)(1) addition to tax.
Background
Some of the facts have been stipulated and are so found.
At the time that the petition was filed, petitioner resided in
Kokomo, Indiana.
During 1997, petitioner lived in a house owned by his
mother. He did not pay any rent to live there, but he did pay,
or contribute to, the cost of certain utilities. The house has
four bedrooms, one of which was used exclusively by petitioner’s
mother. Another bedroom was used by petitioner and, from time to
time during 1997, petitioner’s brother. The remaining two
bedrooms were shared by three of petitioner’s nephews
(petitioner’s nephews), all of whom lived in petitioner’s
mother’s house throughout 1997.
In 1991, petitioner’s nephews were abandoned by their
parents (petitioner’s sister and former brother-in-law), and they
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