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control of his father and only occasionally visited petitioner.
Petitioner contests respondent's determination, contending that
Syme, who turned 16 years old in 1984, lived with her and was in
her actual custody during these years. We have found that Syme
lived in Florida with his father, Clarence, during 1983 and
during the majority of 1984 and that petitioner provided no
support for Syme during the time he lived with Clarence.
To determine whether Syme was a dependent of petitioner’s
during 1983 and 1984, we apply the special test for determining
support in the case of children of divorced parents found in
section 152(e). We apply section 152(e) as in effect prior to
the amendment. Syme lived with Clarence during 1983 and during
the majority of 1984; petitioner, Syme’s custodial parent,
provided no support to him while he lived with his father. We
are persuaded that, during 1983 and 1984, Clarence provided at
least $1,200 a year in support to Syme. Petitioner also has
failed to prove that she provided more of Syme’s support than did
Clarence during 1983 and 1984. Thus, under the special rule of
section 152(e)(2)(B), Clarence is deemed to have provided over
half of Syme’s support for those years. For 1983 and 1984, Syme
was Clarence’s dependent, not petitioner’s. See sec. 152(a).
Accordingly, petitioner is not entitled to an additional
exemption for Syme for 1983 and 1984. See sec. 151(c).
Respondent’s determination of deficiencies is sustained to the
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