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Section 1.152-1(b), Income Tax Regs., provides that section
152(a)(9) applies to an individual who lived with the taxpayer
and was a member of the taxpayer's household during the entire
taxable year of the taxpayer. Because Lynn, Bob, and Robin did
not live with petitioner and were not members of petitioner's
household during the entire calendar year 1993, they do not
qualify as petitioner's dependents for that year. Accordingly,
we sustain respondent's determination on this matter.
James may have lived with petitioner and may have been a
member of petitioner's household during the entire calendar year
1994. Assuming arguendo that such was the case, James still does
not qualify as petitioner's dependent because petitioner failed
to establish that he provided more than half of James' support.
In applying the support test, we evaluate the amount of
support furnished by the taxpayer as compared to the total amount
of support received by the claimed dependent from all sources.
Turecamo v. Commissioner, 554 F.2d 564, 569 (2d Cir. 1977), affg.
64 T.C. 720 (1975); sec. 1.152-1(a)(2)(i), Income Tax Regs. In
other words, in order to establish that the taxpayer provided
more than half of the claimed dependent's support, the taxpayer
must first show, by competent evidence, the total amount of
support received by the claimed dependent from all sources during
the year in issue. Otherwise, the taxpayer cannot be said to
have established that he or she provided more than half of the
support for the claimed dependent. E.g., Blanco v. Commissioner,
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