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nine units. In the fall semester, from August 21 through
December 23, Ms. Santilla completed six units. According to SDMC
requirements, students with 6 units are “half-time”, students
with 9 units are “3/4 time”, and students with 12 units are
“full-time”. Throughout the year, Ms. Santilla was employed by
Charlotte Russe, Carmel Mountain Preschool, and KinderCare
Learning Centers. Ms. Santilla filed a Federal income tax return
for taxable year 2000 on which she reported gross income of
$4,002.
Subject to restrictions not applicable here, a taxpayer is
entitled to a dependency exemption deduction for a dependent who
meets one of two requirements in a given taxable year. Sec.
151(a), (c)(1). The dependent must either (a) have gross income
during the year in an amount that is less than the exemption
amount, or (b) be a child of the taxpayer who meets the age
requirement. Sec. 151(c)(1)(A), (B). To meet the age
requirement, the child must be under the age of 19 at the end of
the year or a “full-time student” under the age of 24. Sec.
151(c)(1)(B), (4). To be a full-time student within the meaning
of the statute, the child must be enrolled “for the number of
hours or courses which is considered to be full-time attendance”
in at least some part of 5 different months of the year. Sec.
1.151-3(b), Income Tax Regs.
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Last modified: May 25, 2011