- 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
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