Renee Muhammad - Page 5

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          employment as a teacher as opposed to personal expenditures made            
          for herself or made gratuitously for her students.  She has not             
          provided any evidence that would substantiate an allowance of               
          itemized deductions in excess of those allowed by respondent.               
          Respondent's determination is sustained.                                    
               For eligible individuals, section 25A allows credits against           
          tax for qualified tuition and related expenses paid by the                  
          taxpayer during the taxable year.  The Hope Scholarship Credit              
          applies to 100 percent of so much of the qualified tuition and              
          related expenses paid by the taxpayer during the taxable year               
          (for education furnished to the eligible student during any                 
          academic period beginning in such taxable year) as does not                 
          exceed $1,000, plus 50 percent of such expenses so paid as                  
          exceeds $1,000 but does not exceed the applicable limit.  Sec.              
          25A(b).  In order to be eligible for the Hope Scholarship Credit,           
          a student must be enrolled at least half time at an eligible                
          educational institution for any portion of the taxable year.                
          Sec. 25A(b)(2)(B) and (3).                                                  
               The Lifetime Learning Credit is an amount equal to 20                  
          percent of so much of the qualified tuition and related expenses            
          paid by the taxpayer during the taxable year (for education                 
          furnished during any academic period beginning in such taxable              
          year) as does not exceed $5,000 in the case of taxable years                
          beginning before January 1, 2003.  See sec. 25A(c).  Section                






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