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petitioner is property of Mrs. Roberts. Thus to the extent that
these funds were used to support Nicole, at best each spouse
contributed exactly one half of Nicole's support and not over one
half, as required by statute. Jorg v. Commissioner, 52 T.C. 288
(1969); Ketcham v. Commissioner, T.C. Memo. 1982-637.
Accordingly, petitioner is not entitled to an exemption deduction
for Nicole.
Schedule A Itemized Deductions
In the notice of deficiency, respondent determined that
petitioner was entitled to the zero bracket amount. Petitioner
contends that he is entitled to Schedule A itemized deductions.
Specifically, petitioner contends that he is entitled to the
following itemized deductions that he claimed on the California
return:
Expense Amount
Medical/dental $150
Real estate tax 850
General sales tax 1,300
Auto license 138
Home mortgage interest 5,640
Lot interest 1,590
Charitable contributions 2,900
Union dues 252
Lawyer/accountant fees 300
Small engine tools 179
Deductions are a matter of legislative grace, and the
taxpayer bears the burden of proving that he or she is entitled
to any deduction claimed. New Colonial Ice Co. v. Helvering, 292
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