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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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