Daniel Aaron Baker - Page 10

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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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