Tam N. Huynh - Page 12




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          Federal income tax return.  Petitioner sent documents to                    
          respondent showing that during 1998 he received public assistance           
          of $1,584 from the Fairfax County Department of Human Development           
          (FCDHD), and that during the period between December 1, 1998, and           
          December 1, 1999, petitioner received housing assistance of                 
          $9,036 from the U.S. Department of Housing and Urban Development            
          (HUD).  Petitioner did not send to respondent any documents that            
          showed how much assistance he received from HUD prior to December           
          1, 1998.                                                                    
               Respondent’s position in the administrative and litigation             
          proceedings was that petitioner did not establish that he                   
          furnished over half the support of his three children during                
          1998.  Respondent received the following documentation from                 
          petitioner in support of petitioner’s claimed dependency                    
          exemptions:  (1) An account ledger maintained by the apartment              
          building where petitioner lived indicating that petitioner paid             
          rent of $176 each month during 1998; (2) monthly phone bills                
          ranging from $37 to $269 during 1998; and (3) an account                    
          statement indicating that during 1998 petitioner’s monthly                  
          utility bills ranged from $49 to $125, prior to adjustment for              
          “energy assistance”.                                                        
               On this record, we conclude that respondent’s position                 
          denying petitioner dependency exemptions for his children during            








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