Thomas Samuel Lear - Page 4

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          provided by all sources for the relevant year must be established           
          by competent evidence.  Blanco v. Commissioner, supra at 514.  To           
          determine whether a taxpayer provided more than half of the                 
          support for a dependent, the amount of support provided by the              
          taxpayer is compared to the dependent’s total amount of support.            
          Sec. 1.152-1(a)(2)(i), Income Tax Regs.  The value of support in            
          the form of lodging is measured by its fair rental value.  Blarek           
          v. Commissioner, 23 T.C. 1037, 1039 (1955).                                 
               We found petitioner to be forthright and candid and his                
          testimony to be credible.  Petitioner testified about various               
          amounts he expended to support Amy.  Petitioner, however, did not           
          establish the fair rental value of the lodging supplied by Ms.              
          Lear, nor did petitioner establish the total amount of support              
          provided for Amy in 2000.  We therefore sustain respondent’s                
          determination that petitioner is not entitled to a dependency               
          exemption deduction for Amy.                                                
          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 defined as either “any individual who              
          has a qualifying child for the taxable year” or any individual              
          who does not have a qualifying child and who meets the                      
          requirements of section 32(c)(1)(A)(ii).  Merriweather v.                   
          Commissioner, T.C. Memo. 2002-226.  A “qualifying child” is                 

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