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Finally, respondent disallowed a dependency exemption that
petitioners claimed for petitioner’s brother, James Choi.
Respondent determined that petitioners were not entitled to claim
the exemption because they had not shown that they provided more
than one-half of the support for James Choi as required under
sections 151(c) and 152(a). Petitioners must show that they
provided more than 50 percent of the support to be entitled to
claim the dependency exemption for 1991 and 1992. See Morrison
v. Commissioner, T.C. Memo. 1975-73; Johnson v. Commissioner,
T.C. Memo. 1974-150.
Respondent contends that the evidence shows that James Choi
worked full time in Gene’s in exchange for the payment of his
living expenses. Petitioners did not brief this issue and have
not shown that they provided more than one-half of James Choi’s
support. Accordingly, we hold that petitioners are not entitled
to the claimed dependency exemption.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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