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Name Relationship Notice Date ITIN
Benjamin Vega father Aug. 9, 1999 979-xx-xxxx
Margarita Campos mother Aug. 9, 1999 979-xx-xxxx
Jose De Jesus Vega brother Oct. 14, 1999 983-xx-xxxx
Rafael Vega brother Sept. 20, 1999 983-xx-xxxx
Cleofas Gabriela Vega sister July 9, 1999 980-xx-xxxx
Liliana Margarita Vega sister Mar. 6, 2000 990-xx-xxxx
In June 2000, respondent’s Appeals Office in Laguna Niguel,
California, issued a notice of deficiency to petitioner
determining deficiencies in his Federal income taxes for 1996 and
1997. The explanation of adjustments in the notice of
deficiency, together with the Appeals Office narrative, indicates
that petitioner satisfied all but one of the requirements for the
allowance of dependency exemptions, namely, that the taxpayer
include on the taxpayer’s return the identifying number of each
individual who is claimed as a dependent.
OPINION
As a preliminary matter, we note that deductions are
strictly a matter of legislative grace, and a taxpayer must
satisfy the specific requirements for any deduction claimed. See
New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934).
Issue (1): Dependency Exemptions
A taxpayer is entitled to a deduction for an exemption for
each individual who qualifies as the taxpayer’s dependent under
sections 151 and 152. Secs. 151(a), (c), and 152. However,
section 151(e) limits this allowance by providing that “No
exemption shall be allowed under this section with respect to any
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