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A child of the taxpayer is considered a “dependent” so long as
the child has not attained the age of 19 at the close of the
calendar year in which the taxable year of the taxpayer begins,
and more than half the child’s support for the taxable year was
received from the taxpayer. Secs. 151(c)(1)(B), 152(a)(1). The
age limit is increased to 24 if the child was a student as
defined by section 151(c)(4). Sec. 151(c)(1)(B).
In 2002, MA received Social Security benefits of $5,168 for
her support. In order for petitioner to meet the support
requirement under section 152(a), she must show that she paid
more than $5,168 for MA’s support in 2002. Petitioner failed to
provide any documentation to support her contention that she
provided for more than half of MA’s support in 2002.
Accordingly, respondent’s determination disallowing the
exemption deduction is sustained.
IV. Accuracy-Related Penalty
Respondent determined that petitioner is liable for an
accuracy-related penalty under section 6662(a). Section 6662(a)
imposes a 20-percent penalty on the portion of an understatement
attributable to any one of various factors, including negligence
or disregard of rules or regulations and a substantial
understatement of income tax. See sec. 6662(b)(1) and (2).
“Negligence” includes any failure to make a reasonable attempt to
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Last modified: May 25, 2011