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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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Last modified: May 25, 2011