- 7 -
devoid of any reference to the dollar amount of total support
that RJM and CGM received in State aid, and the dollar amount of
support that petitioner provided for his nieces. Thus,
petitioner has failed to provide the Court with any evidence
establishing the total amount of support that his nieces
received, or that he provided over half of his nieces’ support
during the 2003 tax year. Accordingly, the Court is constrained
to conclude that petitioner is not entitled to dependency
exemptions for his nieces.
II. Head of Household Filing Status
Section 1(b) imposes a special tax rate on an individual
filing his Federal tax return as head of household. Section 2(b)
defines a “head of household” as an individual taxpayer who is:
(1) Unmarried at the close of the taxable year; and (2) maintains
as his home a household which constitutes for more than one-half
of the taxable year the principal place of abode of a dependent
of the taxpayer with respect to whom the taxpayer is allowed a
deduction under section 151. Sec. 2(b)(1)(A)(i) and (ii). This
Court has already concluded that petitioner is not entitled to
dependency exemptions under section 151 for RJM and CGM.
Accordingly, a fortiori, petitioner is not entitled to head of
household filing status.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: November 10, 2007