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Anaheim apartment often. At that time, Corey was enrolled in
Stoddard Elementary School in Anaheim. All report cards were
signed by Ms. White as Corey’s parent or legal guardian. The
Whites and Corey moved to Rouses Point, New York, in September
1996 to be with Ms. White’s sister who was diagnosed with cancer.
Corey was enrolled into Rouses Point Elementary School on October
1, 1996.
After Corey and the Whites moved to Rouses Point, petitioner
sent approximately $150 per month for Corey’s support. Corey
wrote petitioner often and informed petitioner of items he wanted
or needed, e.g., ice skates for hockey, video games, and
clothing. Petitioner shipped these items directly to Corey.
On petitioner’s 1996 Federal income tax return, petitioner
reported wages of $14,066. She also claimed a dependency
exemption deduction for Corey and an earned income credit.
Respondent disallowed the dependency exemption because petitioner
failed to establish that she was entitled to the exemption.
Respondent further determined that petitioner was not entitled to
the earned income credit.
Dependency Exemption
Section 151(c) allows a taxpayer to deduct an annual
exemption amount for each child under the age of 19 who is a
dependent of the taxpayer. A “dependent” is defined in section
152(a) as an individual “over half of whose support, for the
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Last modified: May 25, 2011