- 18 -
place of abode of the taxpayer’s father or mother but only if
such parent qualifies as the taxpayer’s dependent under sections
151 and 152. Sec. 2(b)(1).
We have already held that petitioner is not entitled to
deductions for exemptions for his parents for 1998 and 1999
because they do not qualify as petitioner’s dependents under
sections 151 and 152. Accordingly, petitioner does not qualify
as a head-of-household for either of those years. Sec. 2(b)(1).
Because petitioner was unmarried, his filing status is “single”,
see secs. 1(c), 3(c), and he is entitled to the standard
deduction applicable to that particular filing status, see sec.
63(c). Accordingly, we sustain respondent’s determination on
this issue.
E. Schedule C Deductions
As relevant to the issues for decision, petitioner claims
that he is entitled to deductions for business expenses as
follows: (1) Rent of $11,100 and $5,550 for 1998 and 1999,
respectively, (2) repairs and maintenance of $141 for 1998, (3)
utility expenses of $510 and $549 for 1998 and 1999,
respectively, and (4) telephone expenses of $498 and $544 for
1998 and 1999, respectively.
Deductions are a matter of legislative grace, and the
taxpayer bears the burden of proving that he or she is entitled
to any deduction claimed. Rule 142(a); New Colonial Ice Co. v.
Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NextLast modified: May 25, 2011