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Respondent determined a deficiency of $5,183 in petitioner’s
Federal income tax for the year 2001.
The issues for decision are whether petitioner is entitled
to: (1) Head-of-household filing status under section 2(b); (2)
dependency exemption deductions for three children under section
152; (3) an earned income credit under section 32(a); (4) a child
and dependent care credit under section 21(a)(1); and (5) a child
tax credit under section 24.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits received into evidence
are incorporated herein by reference. At the time the petition
was filed, petitioner resided in Fresno, California.
Petitioner was employed as a medical assistant during the
year 2001. She filed her return for 2001 as a head of household.
She reported gross income of $18,331 and claimed dependency
exemptions for three children, an earned income credit of $2,904,
a child care credit of $13, and a child tax credit of $833.
Respondent issued a notice of deficiency determining that
petitioner was not entitled to head-of-household filing status,
the claimed dependency exemption deductions, the earned income
credit, the child care credit, and the child tax credit because
she failed to substantiate her entitlement to them.
Deductions are a matter of legislative grace, and taxpayers
must maintain adequate records to substantiate the amounts of any
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