Brian Timothy Brunner - Page 7

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          week.  IRS Publication 505, Tax Withholding and Estimated Tax, at           
          10 (Rev. December 1997 ed.).  Petitioner’s argument that                    
          respondent should have taken into account his claimed 10                    
          exemptions based on an awareness of petitioner’s Form W-4                   
          declaration is misplaced.                                                   
               Petitioner is entitled to a deduction for at least one                 
          exemption for himself pursuant to section 151(b).  In addition,             
          an exemption is also allowed for each dependent.  In cases where            
          a joint return is not filed, an additional exemption is permitted           
          for a spouse only if the spouse does not have any gross income              
          and “is not the dependent of another taxpayer”.  Sec. 151(b).  In           
          order for a “son or daughter of the taxpayer” to be considered a            
          dependent for 1997, the child must receive over half of his or              
          her support from the taxpayer during the 1997 taxable year.                 
          Section 152(a)(1).  If the child’s income for 1997 exceeded                 
          $2,650, the child must also be under age 20 or a student under              
          age 24 at December 31, 1997.  Sec. 151(c)(1).                               
               However, no exemption is allowed for any individual unless a           
          Taxpayer Identification Number (TIN) for the individual is                  
          provided on the return claiming the exemption.  Sec. 151(e).3               

               3 Sec. 151(e) provides:                                                
                    SEC. 151 (e).  Identifying Information Required.--                
               No exemption shall be allowed under this section with                  
               respect to any individual unless the TIN of such                       
               individual is included on the return claiming the                      
                                                             (continued...)           





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