- 4 - A. Dependency Exemption Deduction A taxpayer may be entitled to claim a dependency exemption deduction for each individual who qualifies as the taxpayer’s dependent under sections 151 and 152. Secs. 151(a), (c), and 152. An individual must meet the following five tests in order to qualify as a dependent of the taxpayer: (1) Support test; (2) relationship or household test; (3) citizenship or residency test; (4) gross income test; and (5) joint return test. Secs. 151 and 152. As relevant herein, the citizenship or residency test requires that the dependent be a U.S. citizen or national, or resident of the United States, Canada, or Mexico at some time during the calendar year in which the taxable year of the taxpayer begins. Sec. 152(b)(3); sec. 1.152-2(a)(1), Income Tax Regs. On their 2000 return, petitioners claimed a dependency exemption deduction for S.G. In the notice of deficiency, respondent disallowed the exemption on the basis that S.G. failed to qualify as a dependent under the citizenship or residency test. S.G. is not a U.S. citizen or national, or resident of the United States, Canada, or Mexico. Rather, S.G. is a British citizen. Moreover, petitioners and S.G. resided in thePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011