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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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Last modified: May 25, 2011