Jean G. Joseph - Page 4

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          Dependency Exemption Deduction                                              
               Petitioner argues that he is entitled to claim a dependency            
          exemption deduction with respect to Dina.  Sections 151 and 152             
          provide that a taxpayer is entitled to deduct an exemption for a            
          minor dependent if the taxpayer provides more than half of the              
          support for the minor dependent.  A daughter of a taxpayer is               
          included in the definition of a dependent.  Sec. 152(a)(1).  The            
          issue with regard to the dependency exemption deduction claimed             
          by petitioner is whether petitioner established that he provided            
          more than half of the support for Dina.                                     
               Petitioner claims that he paid approximately $600 per month            
          for food, clothing, etc., and $500 per month for housing for the            
          support of Ms. Duverger, Dina, the other child, and himself,                
          totaling $1,100 per month.  Petitioner has no records                       
          establishing these amounts.  We pointed out at trial that the               
          total support he allegedly paid per year would have been $13,200,           
          approximately $5,000 more than his reported taxable income.  He,            
          therefore, either understated his taxable income or overstated              
          the amount that he allegedly paid for support.  Moreover,                   
          petitioner had no idea what the total cost for support was or               
          what the total cost was for the support of Dina.  Given that Ms.            
          Duverger had a taxable income of more than twice the amount                 









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