Joseph Lee Marshall - Page 9




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               As previously indicated, petitioner offered little evidence            
          as to the total sources of support or his share of support for FA           
          and AA.  Both petitioner and Ms. Briscoe helped pay for food and            
          utilities when they lived with petitioner’s mother, but neither             
          paid rent.  While petitioner may have paid for room and board, we           
          have little information as to the total expenditures to support             
          the children during the period January to August 2005.  After               
          petitioner moved with Ms. Briscoe and the children in August of             
          2005, petitioner paid one-half the rent for a period of time.  At           
          some point during or after September 2005, petitioner paid the              
          entire rent.  There is still insufficient evidence in this record           
          to establish the total cost of the children’s support during this           
          period, and thus petitioner failed to establish that he provided            
          more than half of the children’s support for 2005.  Petitioner              
          has failed to prove that either FA or AA is a qualifying                    
          relative.                                                                   
               Neither FA nor AA may be considered a qualifying child or a            
          qualifying relative; therefore, neither child may be considered             
          petitioner’s dependent.  Petitioner is not entitled to a                    
          dependency exemption deduction for FA or AA.  Respondent’s                  
          determination on this issue is sustained.                                   
          B.  Child Tax Credits                                                       
               Section 24(a) provides for a “credit against the tax * * *             
          for the taxable year with respect to each qualifying child of the           







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