Ann M. Wilson - Page 8

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          move with her to San Diego.  Instead, RW remained in Indiana,               
          completed her eighth-grade year, then came to San Diego for the             
          summer after the end of the school year.  RW had expressed                  
          reservations about living in San Diego and convinced petitioner             
          to allow her to remain in Indiana to attend high school for the             
          next 4 years.                                                               
               Accordingly, petitioner did not maintain a principal place             
          of abode for RW within the meaning of the statute.  RW did not              
          move to San Diego to live with petitioner permanently.  RW did              
          not consider petitioner’s home in San Diego as her principal                
          place of abode; therefore, petitioner did not maintain her home             
          as the principal place of abode for RW.                                     
               A temporary absence, however, where the child fails to                 
          occupy the abode because of special circumstances, such as                  
          education or vacation, and where the child is absent for less               
          than 6 months of the taxable year of the taxpayer, will not                 
          prevent the taxpayer from claiming the status of head of                    
          household.  Sec. 1.2-2(c)(1), Income Tax Regs.  A child’s absence           
          will not prevent the taxpayer from being considered as                      
          maintaining a household if:  “(i) it is reasonable to assume that           
          the taxpayer or such other person will return to the household,             
          and (ii) the taxpayer continues to maintain such household or a             
          substantially equivalent household in anticipation of such                  
          return.”  Id.                                                               






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