Sheila Mae Howard - Page 18

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          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           
               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.           

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