Richard J. Sarni and Susan Sarni - Page 5

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          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 the                     







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