Robert Terrence Thompson - Page 5

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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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