Marcel Toto Ngosso - Page 12

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          the taxpayer and is a member of the taxpayer’s household.  Sec.             
          152(a)(9).  It is necessary that the taxpayer both maintain and             
          occupy the household.  Sec. 1.152-1(b), Income Tax Regs.  It is             
          not necessary that the dependent be related to the taxpayer.  Id.           
               The term “support” includes food, shelter, clothing, medical           
          and dental care, education, and the like.  Sec. 1.152-1(a)(2)(i),           
          Income Tax Regs.  The amount of support that the claimed                    
          dependent received from the taxpayer is compared to the total               
          amount of support the claimed dependent received from all                   
          sources.  Id.  The total amount of support for each claimed                 
          dependent furnished by all sources during the year in issue must            
          be established by competent evidence.  Blanco v. Commissioner, 56           
          T.C. 512, 514 (1971).                                                       
               Petitioner’s testimony that he provided Shanita’s food and             
          shelter lacks credibility, and we need not accept it.  Tokarski             
          v. Commissioner, 87 T.C. 74, 77 (1986).  Additionally, petitioner           
          did not provide any documentary evidence to support his                     
          testimony.  We are not convinced that petitioner provided more              
          than half of Shanita’s support.  Moreover, it is not clear that             
          Shanita had petitioner’s apartment as her principal place of                
          abode during 1996.  Accordingly, the claimed dependency exemption           
          deduction for Shanita is denied.                                            
               The next issue for our decision is whether petitioner is               
          liable for a penalty under section 6662.  Section 6662 provides             

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