Curtis D. Custis - Page 7

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          with regard to AC from sources other than petitioner.  No                   
          documentation concerning the support of either petitioner’s son             
          or niece was provided.                                                      
               Petitioner failed to establish that he provided more than              
          one-half of the total support for either IC or AC.  Additionally,           
          IC’s mother, and not petitioner, is IC’s custodial parent and did           
          not sign a written declaration allowing petitioner to take                  
          dependency exemption deduction.  For the foregoing reasons,                 
          petitioner has not satisfied the burden of proof with regard to             
          the claimed dependency exemptions.  Respondent’s determinations             
          disallowing the dependency exemptions are sustained.                        
          2.   Head of Household Status                                               
               Section 1(b) imposes a special income tax rate on an                   
          individual filing as head of household.  As applied in this                 
          context, section 2(b) defines “head of household” as an unmarried           
          individual who maintains as his home a household which                      
          constitutes for more than one-half of the taxable year the                  
          principal place of abode of a son, or “any other person who is a            
          dependent of the taxpayer, if the taxpayer is entitled to a                 
          deduction for the taxable year for such person under section                
          151”.  Sec. 2(b)(1)(A)(i) and (ii).                                         
               Because petitioner did not maintain a household which was              
          for more than half the year IC’s principal place of abode and               
          because petitioner is not entitled to the dependency exemption              

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