Atoumane Ndoye - Page 5




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          determination is presumed to be correct, and petitioner must                
          prove it wrong.  Welch v. Helvering, 290 U.S. 111, 115 (1933).              
          1.  Dependency Exemption                                                    
               Section 151(c) allows a taxpayer to claim as a deduction an            
          exemption amount for each of his or her dependents.  Sections 151           
          and 152 lay out the following five tests that a taxpayer must               
          meet in order to claim another person as a dependent: (1) Support           
          test, (2) relationship or household test, (3) citizenship or                
          residency test, (4) gross income test, and (5) joint return test.           
          If the taxpayer fails any of these tests, he or she may not claim           
          the person as a dependent.                                                  
               As to the support test, the taxpayer must provide over half            
          of a claimed dependent’s support for the calendar year in which             
          the taxable year of the taxpayer begins.  Sec. 152(a).  The                 
          support test requires the taxpayer to establish the total support           
          costs for the claimed individual and that the taxpayer provided             
          at least half of that amount.  Archer v. Commissioner, 73 T.C.              
          963, 967 (1980); see Cotton v. Commissioner, T.C. Memo. 2000-333;           
          Gulvin v. Commissioner, T.C. Memo. 1980-111, affd. 644 F.2d 2               
          (5th Cir. 1981); Toponce v. Commissioner, T.C. Memo. 1968-101.  A           
          taxpayer who cannot establish the total amount of support costs             
          for the claimed individual generally may not claim that                     
          individual as a dependent.  Blanco v. Commissioner, 56 T.C. 512,            
          514-515 (1971); Cotton v. Commissioner, supra.                              






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