- 4 - In the notice of deficiency, respondent disallowed petitioner’s dependency exemption deduction for L.H. on the ground that petitioner failed to establish that she provided more than half the support for the child. The record shows that all members of petitioner’s household, including petitioner, deposited their earnings in one bank account. All household expenses were paid out of that account. In the audit of petitioner’s tax return, respondent determined that, for the year at issue, petitioner’s earnings of $13,285 in that account and the earnings of the other members of her household totaled $32,164.59. Respondent further determined that this account also included assistance payments from the State of Washington during the year at issue for the benefit of L.H. These payments were identified at trial as “WIC” payments. Because this account represented the total income of petitioner and members of her family, respondent determined that the greater portion of the support provided to L.H. during the year came from persons other than petitioner. Thus, respondent determined that petitioner was not entitled to the dependency exemption deduction she claimed on her 2001 tax return. The Court is satisfied from the record and from the evidence at trial that petitioner did not provide more than one-half the support of L.H. during the year at issue. The general rule under section 151 is that the dependency exemption deduction isPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011