Marcel Toto Ngosso - Page 11

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          satisfied that petitioner underreported income, and respondent is           
          sustained on this issue.                                                    
               The next issue for our decision is whether petitioner is               
          entitled to the claimed dependency exemption deduction.                     
          Petitioner claimed a dependency exemption deduction for Shanita             
          Edwards (Shanita) on his return for 1996.  Shanita, who was born            
          in 1984, is the daughter of Barbara Nicholson (Ms. Nicholson),              
          who was petitioner’s girlfriend during the year at issue.                   
               Petitioner testified generally that he provided for all of             
          the food and shelter for Shanita, and that Ms. Nicholson provided           
          for only Shanita’s clothing.  Petitioner admitted that he did not           
          know whether Shanita’s father or any other relative provided any            
          of her support, and he did not know whether Ms. Nicholson                   
          received any form of Government benefit.  Petitioner produced               
          copies of Shanita’s birth certificate and Social Security card.             
               Petitioner alleges that Shanita, Ms. Nicholson, and Kimberly           
          Nicholson (Kimberly), also a minor and a daughter of Ms.                    
          Nicholson, lived with him in his apartment in Silver Spring,                
          Maryland, during 1996.  Petitioner also alleges that Guy Behl               
          (Mr. Behl) lived in his apartment during 1996.                              
               A taxpayer may be allowed a deduction for a dependent over             
          half of whose support is provided by the taxpayer.  Secs.                   
          151(c)(1), 152(a).  A dependent includes an individual who, for             
          the taxable year, has as her principal place of abode the home of           

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