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not all made out to Lydia Smith, as would be expected by the
support arrangement described by petitioner. Additionally, the
checks are all dated during the taxable years 2004 and 2005.
We are convinced that, during 2003, petitioner paid various
expenses for DS and was a caring uncle to DS. However,
petitioner has failed to provide the Court with any significant
corroborative evidence showing that he provided over half of DS’s
support during the 2003 taxable year.
Upon the basis of the record before us, we cannot find that
petitioner has established the total support costs for DS during
taxable year 2003, nor has he established that he provided at
least half of that amount. Respondent’s determination on this
issue is sustained.
2. Head of Household
As previously stated, petitioner claimed head-of-household
filing status on his 2003 Federal income tax return, and
respondent changed the filing status to single in the notice of
deficiency.
Section 1(b) imposes a special income tax rate on an
individual filing as head of household. Section 2(b) provides
the requirements for head-of-household filing status. As
relevant here, to qualify as a head of a household a taxpayer
must (a) be unmarried at the end of the taxable year, (b) not be
a surviving spouse, and (c) maintain as the taxpayer’s home a
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