Maria Rosa Bland - Page 6

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          proof has not shifted to respondent with respect to any of the              
          issues in the present case.                                                 
               Moreover, deductions are a matter of legislative grace and             
          are allowed only as specifically provided by statute.  INDOPCO,             
          Inc. v. Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice              
          Co. v. Helvering, 292 U.S. 435, 440 (1934).                                 
          1.  Deduction for Dependency Exemption                                      
               Section 151 allows as a deduction an exemption for each                
          dependent of the taxpayer.  See sec. 151(c).  Section 152(a)                
          defines the term “dependent”, in pertinent part, to include “An             
          individual * * * who, for the taxable year of the taxpayer, has             
          as his principal place of abode the home of the taxpayer and is a           
          member of the taxpayer’s household”, provided that more than half           
          of the individual’s support, for the calendar year was received             
          from the taxpayer.  “Support” includes “food, shelter, clothing,            
          medical and dental care, education, and the like.”  Sec. 1.152-             
          1(a)(2)(i), Income Tax Regs.                                                
               In determining whether an individual received more than one-           
          half of his or her support from the taxpayer, there shall be                
          taken into account the amount of support received from the                  
          taxpayer as compared to the entire amount of support which the              
          individual received from all sources.  Id.  In other words, the             
          support test requires the taxpayer to establish the total support           
          costs for the claimed individual and that the taxpayer provided             






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