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family. On or shortly after March 3, 1999, Ms. Thompson returned
Christopher to his mother in Las Vegas.
On or shortly after June 13, 1999, Christopher was again
brought to Chicago for another visit with petitioner and his
family. On or shortly after September 5, 1999, Christopher was
returned to his mother in Las Vegas.
Petitioner filed a Federal income tax return for 1999. On
his return, petitioner listed his filing status as head of
household, and he claimed both a deduction for a dependency
exemption for Christopher and an earned income credit based on
Christopher as the qualifying child. Also on his return,
petitioner reported adjusted gross income in the amount of
$21,499.
Discussion
A. Deduction for Dependency Exemption
Section 151(a) authorizes deductions for the exemptions
provided by that section. In particular, and as relevant herein,
section 151(c)(1)(B) provides an exemption for each dependent, as
defined in section 152, who is a child of the taxpayer and who
has not attained the age of 19 at the close of the calendar year
in which the taxable year of the taxpayer begins.
As relevant herein, section 152(a)(1) defines the term
“dependent” to include a taxpayer’s child over half of whose
support, for the calendar year in which the taxable year of the
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