Roland Gyula Szasz - Page 17

                                       - 16 -                                         
               C.  Dependency Exemption Deductions                                    
               On each of his returns for 1998 and 1999, petitioner claimed           
          dependency exemption deductions for both of his parents.  In the            
          notice of deficiency, respondent denied the deductions.                     
               A taxpayer is entitled to a deduction for an exemption for             
          each individual who qualifies as the taxpayer’s dependent under             
          sections 151 and 152.  Secs. 151(a), (c), 152.  The term                    
          “dependent” includes a taxpayer’s parents over half of whose                
          total support is received from the taxpayer for the calendar                
          year.  Sec. 152(a)(4).  “The term ‘support’ includes food,                  
          shelter, clothing, medical and dental care, education, and the              
          like.”  Sec. 1.152-1(a)(2)(i), Income Tax Regs.                             
               Petitioner contends that he contributed over half of his               
          parents’ total support.  In support of this contention,                     
          petitioner introduced at trial a worksheet indicating that his              
          parents’ sole source of income was Lorant’s annual Social                   
          Security benefits of approximately $9,036, that his parents’                
          total support cost was $34,625, and that petitioner contributed             
          $25,588 towards his parents’ support.9  We do not find the                  
          worksheet to be reliable because petitioner did not have personal           
          knowledge of the information in the worksheet, which was                    
          completed by Lorant, and petitioner did not present any testimony           


               9  We note that the worksheet erroneously counted rent for             
          the Victorville home as an expense of the entire household and as           
          another separate expense of the dependents.                                 





Page:  Previous  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  Next

Last modified: May 25, 2011