Etta James Linton, a.k.a. Ella Jane Linton - Page 5

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          in the home of their foster parents.  Accordingly, we conclude              
          that petitioner is not entitled to head of household filing                 
          status.                                                                     
          II.  Dependency Exemptions                                                  
               A taxpayer may claim exemptions for individuals who qualify            
          as the taxpayer’s dependents.  Sec. 151(a), (c)(1).  Section                
          152(a)(1) includes a taxpayer’s children as dependents if the               
          taxpayer provided over half of their support during the calender            
          year.                                                                       
               Petitioner testified at trial that she occasionally bought             
          food, clothes, school supplies, and toys for Frankie and Avery.             
          Petitioner did not introduce any documentary evidence in support            
          of her testimony.  Even assuming that petitioner’s                          
          unsubstantiated testimony correctly accounts for her                        
          contributions toward Frankie and Avery’s support, petitioner                
          clearly did not provide over half of their support as required by           
          section 152(a).  We therefore sustain respondent’s determination            
          that petitioner is not entitled to claim dependency exemptions              
          for her two sons.                                                           
          III.  Earned Income Credit                                                  
               Section 32(a)(1) provides an income tax credit, subject to             
          limitation by section 32(a)(2), for taxpayers who satisfy certain           
          eligibility requirements.  Pursuant to section 32(c)(1)(A)(i), a            
          taxpayer is eligible for the earned income credit if the taxpayer           






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