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(1) the amount of total support incurred on behalf of A during
2003 and (2) the amount of such support that he provided to A
during that year. During 2003, petitioner, who was a plumber,
had total income and adjusted gross income of $15,349. Ms. Wus
received public assistance from the State of Delaware for the
benefit of A. Moreover, A received healthcare benefits under
Medicaid, and not from petitioner. Although for the period
January 2 through March 31, 2003, both petitioner and Ms. Wus
made payments toward the cost of providing A’s daycare, the
record is devoid of evidence establishing the total amount of
such payments or the amount of such payments that petitioner
made. In addition, Ms. Srase, who usually babysat A approxi-
mately two to three times a week during 2003, often provided food
to A at Ms. Srase’s own expense. Finally, as discussed above,
although petitioner claims that A lived with him during all of
2003 except November and December of that year, his claim is not
supported by evidence that we consider to be reliable.
On the record before us, we find that petitioner has failed
to carry his burden of establishing that he is entitled for his
taxable year 2003 to a dependency exemption deduction for his
daughter A.
Claimed Head of Household Filing Status
Section 1(b) provides a special tax rate for any individual
who qualifies as head of a household. As pertinent here, the
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