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taxpayer claiming the exemption, the child must not have attained
the age of 19 at the close of the calendar year or must be a
student. Sec. 151(c)(1)(B).
During 1987, Sandra had not attained the age of 19 at the
close of the year. However, she had a part-time job at a
supermarket during 1987. Based on petitioner's testimony at
trial, Sandra's gross income from this job was "over $1,900"
during 1987.
Petitioner presented no evidence to establish the total
support provided to Sandra during 1987, and that, of the total
support provided, more than one-half of such amount was provided
by petitioner. See Blanco v. Commissioner, 56 T.C. 512, 514
(1971). Although petitioner provided Sandra with a place of
abode, food, and perhaps some clothing, the record shows, based
on petitioner's testimony, that Sandra had other means of support
during 1987 in addition to the earnings from her part-time job
and petitioner's support. Sandra's father provided her $100 per
week during 1987. On this record, petitioner has not established
that she provided more than half of Sandra's total support during
1987. Respondent, therefore, is sustained on this issue.4
4
Petitioner offered no testimony as to her relationship with
Sandra's father, and, in particular, whether she and Sandra's
father were married to each other; whether they were divorced or
legally separated and, if so, the date thereof, and who was the
custodial parent; and whether there were any agreements or court
decrees regarding which parent was entitled to the dependency
(continued...)
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