Karen Ann Keegan - Page 14

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           her own support.  Sec. 1.152-1(a)(2)(ii), Income Tax Regs.  To                             
           determine whether a taxpayer has furnished over half of an                                 
           individual's support, there must be included the cost of food,                             
           shelter, clothing, medical and dental care, education, and the                             
           like.  Sec. 1.152-1(a)(2)(i), Income Tax Regs.  Although the                               
           amount of an item of support is usually its cost, where lodging                            
           is furnished to an individual, the amount of support is the fair                           
           market value of such lodging.  Id.  Welfare payments or similar                            
           public assistance received directly by a claimed dependent, or                             
           received by the taxpayer for the benefit of a claimed dependent,                           
           are not considered support furnished by the taxpayer.  Gulvin v.                           
           Commissioner, 644 F.2d 2 (5th Cir. 1981), affg. T.C. Memo. 1980-                           
           111; Williams v. Commissioner, T.C. Memo. 1996-126, affd. without                          
           published opinion 119 F.3d 10 (11th Cir. 1997).                                            
                 In cases where two or more persons contribute to the support                         
           of an individual, section 152(c) provides that a taxpayer is                               
           treated as contributing over one-half of the support of an                                 
           individual for the calendar year if:  (1) No one person                                    
           contributed over half of the individual's support; (2) over half                           
           of such support was received from persons each of whom, but for                            
           the fact that he or she did not contribute over half of such                               
           support, would have been entitled to claim such individual as a                            
           dependent for the taxable year beginning in such calendar year;                            
           (3) the taxpayer contributed over 10 percent of such support; and                          

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