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Ms. Santilla does not meet the first requirement for a
dependency exemption under section 151(c)(1)(A). Ms. Santilla
had gross income of $4,002 during 2000, which is in excess of the
exemption amount for that year, $2,800. Sec. 151(d); Rev. Proc.
99-42, sec. 3.09(1), 1999-2 C.B. 568, 571. Ms. Santilla also
does not meet the second requirement for a dependency exemption
under section 151(c)(1)(B). Although Ms. Santilla was a student
at SDMC during both the spring and fall semesters, she was not
enrolled as a full-time student at any time during the year.
SDMC requires that full-time students take 12 units during the
semester; Ms. Santilla never completed more than 9 units during
any one semester.
Because Ms. Santilla did not meet either of the requirements
for a dependency exemption under section 151(c)(1), petitioners
are not entitled to a dependency exemption deduction for her
during the taxable year 2000. Sec. 151(a).
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011