-3-
Welch v. Helvering, 290 U.S. 111, 115 (1933). Moreover,
deductions are a matter of legislative grace, and petitioner
bears the burden of proving that he is entitled to any deduction
claimed. Rule 142(a); New Colonial Ice Co. v. Helvering, 292
U.S. 435, 440 (1934); Welch v. Helvering, supra at 115.
1. Dependency Exemptions
Respondent determined that petitioner is not entitled to
claim any dependency exemptions other than for himself.
Section 151(c)(1) allows a taxpayer to claim an exemption
for each dependent (as defined by section 152) whose gross income
is less than the exemption amount or who is a child of the
taxpayer and meets certain age requirements. Section 152(a)(1)
provides that the term "dependent" includes a taxpayer's child
"over half of whose support, for the calendar year in which the
taxable year of the taxpayer begins, was received from the
taxpayer (or is treated under subsection (c) or (e) as received
from the taxpayer)".
In the case of a child whose parents live apart at all times
during the last 6 months of the calendar year, generally the
custodial parent (i.e., the parent having custody of the child
for the greater portion of the calendar year) is treated as
providing over one-half of the support of the child. Sec.
152(e)(1). An exception to this general rule exists, however,
where the custodial parent signs a written declaration that such
custodial parent will not claim such child as a dependent, and
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