Jerry Howard-Crowley - Page 5

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               After the notice of deficiency was issued, the case was                
          assigned to respondent's Appeals Office for consideration.  While           
          Appeals was considering the case, petitioner submitted a Form               
          1040 for 2000 that listed the income determined in the notice of            
          deficiency and claimed deductions on Schedules A and C.  The                
          parties agree that petitioner was required to file a Federal                
          income tax return for 2000.                                                 
                                     Discussion                                       
               At trial, petitioner argued that he is entitled to                     
          additional deductions for:  (a) A dependency exemption for his              
          daughter; (b) medical expenses; (c) home office expenses; (d)               
          computer expenses; (e) business transportation expenses; and (f)            
          work clothing expenses.  Petitioner failed to meet the                      
          requirements of section 7491(a)(2), and the Court decides this              
          case on the basis of the preponderance of the evidence.                     
          Deductions Petitioner Claimed                                               
               Deduction for Dependency Exemption                                     
               Section 151(c) allows a taxpayer to deduct an exemption                
          amount for each "dependent" as defined in section 152.  Section             
          152(a) defines a dependent to include a son or daughter of the              
          taxpayer "over half of whose support, for the calendar year in              
          which the taxable year of the taxpayer begins, was received from            
          the taxpayer (or is treated under subsection (c) or (e) as                  
          received from the taxpayer)".                                               






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