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than one-half of Jacqueline's support during 1992. Petitioners
assert that they are entitled to the deduction.
Section 151(c)(1) generally allows as a deduction an
exemption for each dependent of a taxpayer as defined in section
152. Section 152(a) provides, in general, that the term
"dependent" means certain individuals over half of whose support
was received from the taxpayer during the taxable year in which
such individuals are claimed as dependents. Eligible individuals
who may be claimed as dependents include, among others, a son or
daughter of the taxpayer. Sec. 152(a)(1). Section 151(c)
further provides that the claimed dependent's gross income for
the taxable year must be less than the exemption amount, or if
the claimed dependent is a child of the 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 who has not
attained the age of 24 at the close of the calendar year. Sec.
151(c)(1)(A) and (B).
During 1992, Jacqueline had attained the age of 20 at the
close of the year but was a student. She maintained a part-time
job during 1992. Based on Jacqueline's 1992 return, her gross
income from wages was $5,182.93.
Petitioner did not present competent evidence to establish
the total support provided to Jacqueline during 1992, and that,
of the total support provided, more than one-half of the amount
was provided by petitioner. See Blanco v. Commissioner, 56 T.C.
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