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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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