LaTanya Haywood - Page 2




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               The issues for decision are: (1) Whether petitioner is                 
          entitled to a dependency exemption deduction under section                  
          151(c)1 for her son, Brandon R. Haywood, and (2) whether                    
          petitioner's son, Brandon R. Haywood, is a qualifying child under           
          section 32(c)(3)(A) so as to increase the amount of the earned              
          income credit under section 32(a) allowable to petitioner.                  
               In the stipulation, respondent conceded the following                  
          adjustments in the notice of deficiency:                                    
               (1) That petitioner was entitled to a dependency exemption             
               deduction for another son, Brent R. Covington;                         
               (2) That petitioner's son, Brent R. Covington, was a                   
               qualifying child under section 32(c)(3)(A) entitling                   
               petitioner to an earned income credit under section 32(a);             
               and                                                                    
               (3) That petitioner was entitled to head-of-household filing           
               status under section 2(b) instead of single as determined in           
               the notice of deficiency.                                              
               With respect to the first issue regarding the dependency               
          exemption deduction claimed for Brandon R. Haywood, section                 
          151(c) allows taxpayers to deduct an annual exemption amount for            
          each dependent as defined in section 152.  Under section 152(a),            


               1    Unless otherwise indicated, all section references are            
          to the Internal Revenue Code in effect for the year at issue.               
          All Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  




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