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reported was based on a cost of $75 per week. Petitioner did not
present any written documentation from Kuddle Korner, the care
provider, although she allegedly showed a letter from a Mrs.
Mankle to the examining agent who questioned the expense.
Respondent allowed a child care credit for 1993 and 1994 but
disallowed the credit for 1995 for lack of substantiation.
Petitioner has a younger sister, Cecilia Ofori. Ms. Ofori,
who is handicapped, resided with petitioner during 1993 and 1994
while attending a trade school. Ms. Ofori was 29 or 30 years old
during that time and had come to the United States from Ghana.
Petitioner contends that she paid all of Ms. Ofori’s expenses in
cash during that period, including tuition, books, clothing,
school supplies, and medicine. Petitioner also claims to have
provided Ms. Ofori’s board and lodging. Ms. Ofori was not
employed, had no income, and did not receive any government
grants, food stamps, or welfare benefits. Petitioner did not
receive financial support from any other sources or family
members for the support of Ms. Ofori.
Petitioner claimed a dependency exemption deduction for Ms.
Ofori for 1993 and 1994 but incorrectly listed as Ms. Ofori’s a
Social Security number that was the Social Security number of one
of petitioner’s daughters. Respondent disallowed the exemption
for Ms. Ofori. Petitioner never provided a correct Social
Security number for her sister, who moved back to Ghana in 1995.
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