Judges have rejected the heads on beds approach for a hybrid of lives in the home and can be claimed as a dependant for tax purposes. See In re Jewell. Having said that, I think that I am seeing fewer challenges on this type of issue from the UST since the administration change. I think the code clearly states heads on beds, and would count them. If they aren’t contributing any $$$ they are essentially dependents – taxwise and otherwise.
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Agreed– heads on beds is proper under the code.