- 6 - 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 anyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011