- 17 - deposits. Finally, respondent then added petitioner’s identified cash expenditures to total net bank deposits to determine petitioner’s unreported income. At trial, petitioner did not question respondent’s determination as to the amount of unreported income she received in 1996 and 1997. Petitioner has not alleged, nor have we discovered, any error in respondent’s income reconstruction using the bank deposits and cash expenditures method. Petitioner produced no evidence of any nontaxable sources for the unexplained funds deposited in her bank account or the cash used to make payments in any of the years in issue. Accordingly, as asserted by respondent at trial, we conclude that petitioner had unreported income in the amounts of $8,856 in 1996 and $23,767 in 1997. D. Dependency Exemption Section 151(c) allows a taxpayer to claim an exemption for each dependent, as defined in section 152. In order to qualify as a dependent, an individual must be related to the taxpayer in one of the ways enumerated in section 152(a)(1) through (8), or, if the individual is unrelated to the taxpayer, the individual must live with the taxpayer and be a member of the taxpayer’s household throughout the entire taxable year of the taxpayer. Sec. 152(a)(9); Trowbridge v. Commissioner, 268 F.2d 208 (9th Cir. 1959), affg. 30 T.C. 879 (1958); Turay v. Commissioner, T.C.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011