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The Court sustains respondent's determination that
petitioner is not entitled to dependency exemption deductions for
Contrille and Brandon in 1997.
2. Head of Household Filing Status
Section 1(b) imposes a special tax rate on individuals
filing as head of household. As relevant herein, section 2(b)
defines a "head of household" as an unmarried individual who
maintains as her home a household that for more than one-half of
the taxable year constitutes the principal place of abode of a
person who is a dependent of the taxpayer, if the taxpayer is
entitled to a deduction for the taxable year for that dependent
under section 151.
Respondent determined that petitioner is not entitled to
section 151 dependency exemption deductions for Contrille and
Brandon in 1997. The Court has sustained respondent's
determination regarding the section 151 deductions. That holding
is dispositive of this issue, and, as a result, the Court
sustains respondent's determination that petitioner is not
entitled to claim head of household filing status for 1997.
3. Earned Income Credit
Section 32(a)(1) allows an eligible individual an earned
income credit against the individual's income tax liability. An
eligible individual is any individual who either: (1) Has a
"qualifying child" as defined by section 32(c)(3)(A), or (2) has
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