Darren M. Parker - Page 5

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          support for the taxable year was received from the taxpayer.                
          Secs. 151(c)(1)(A), 152(a)(9).                                              
               Petitioner has not offered any substantiation to show that             
          he provided more than half of DP’s and EW’s support during 2003.            
          Therefore, petitioner is not entitled to claim DP or EW as                  
          dependents on his 2003 Federal income tax return.                           
               Accordingly, respondent’s determination is sustained.                  
          Earned Income Credit                                                        
               Respondent determined that petitioner is not entitled to an            
          earned income credit for DP and EW, because he failed to                    
          substantiate that DP and EW are “qualifying children”.                      
               Section 32(a)(1) allows an eligible individual an earned               
          income credit against the individual’s income tax liability.                
          Section 32(a)(2) limits the credit allowed, and section 32(b)               
          prescribes different percentages and amounts used to calculate              
          the credit based on whether the eligible individual has no                  
          qualifying children, one qualifying child, or two or more                   
          qualifying children.                                                        
               To be eligible to claim an earned income credit with respect           
          to a qualifying child, a taxpayer must establish, inter alia,               
          that the child bears a relationship to the taxpayer prescribed by           
          section 32(c)(3)(B), that the child meets the age requirements of           
          section 32(c)(3)(C), and that the child shares the same principal           
          place of abode as the taxpayer for more than one-half of the                
          taxable year as prescribed by section 32(c)(3)(A)(ii).                      





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