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and December 1, 1999, but did not show how much housing
assistance he received from HUD prior to December 1, 1998. On
the assumption that petitioner’s housing assistance from HUD did
not significantly change from 1998 to 1999, petitioner’s housing
assistance from HUD nearly matched his total income of $10,698
during 1998.
We hold that respondent was substantially justified in
concluding that petitioner failed to provide sufficient
documentation to establish that he paid over half the cost of
maintaining the household during 1998.
Earned Income Credit
Section 32(a) provides that, subject to limitations, in the
case of an “eligible individual” an earned income credit shall be
allowed against the individual’s income tax liability. Section
32(c)(1)(A) defines an eligible individual as either (1) any
individual who has a qualifying child for the taxable year, or
(2) any other individual who does not have a qualifying child for
the taxable year, if the individual’s principal place of abode is
in the United States for more than one-half of such taxable year,
the individual is at least 25 years of age but has not reached 65
years of age before the close of the taxable year, and the
individual is not a dependent for whom a deduction is allowable
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