David Washington - Page 4




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          qualifying children, stating that they were foster children who             
          resided with him the entire year.                                           
               In the statutory notice of deficiency, respondent changed              
          petitioner’s filing status to married filing separately,                    
          disallowed each of the dependency exemption deductions, and                 
          disallowed the full amount of the claimed earned income credit              
          for taxable year 1999.                                                      
               The first issue for decision is whether petitioner is                  
          entitled to three dependency exemption deductions.                          
               A deduction generally is allowed under section 151(a) for              
          each dependent of a taxpayer.  Sec. 151(a), (c)(1).  Subject to             
          exceptions and limitations not applicable here, an individual is            
          a dependent of a taxpayer only if the taxpayer provides over half           
          of the individual’s support for the taxable year.  Sec. 152(a).             
               During 1999, petitioner resided with Ms. Lipscomb and her              
          three children.  He earned $7,120 during that year, which is the            
          only potential source of support for the children reflected in              
          the record:  Petitioner testified that Ms. Lipscomb was not                 
          receiving any public assistance while being unemployed and having           
          three children to raise.  Despite this testimony, we are                    
          convinced that the children had sources of support other than               
          petitioner.  Petitioner did not directly address what other                 
          sources were available to support the children, nor did he detail           
          any expenses he paid for the children.  See sec. 1.152-1(a),                






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