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extent of the adjustments disallowing additional exemptions for
Syme for 1983 and 1984.
D. Zachary
Petitioner claims an additional personal exemption deduction
for Zachary for 1988, 1989, and 1990. Zachary turned 19 in 1988,
but, during 1988, 1989, and 1990, he was a full-time student.
Thus, petitioner is entitled to an additional personal exemption
deduction for Zachary for 1988 through 1990 if Zachary was
petitioner’s dependent, within the meaning of section 152(a)(1),
for those years.
We need not concern ourselves with the section 152(e) test
for determining support in the case of children of divorced
parents. Under Florida law, Zachary’s minority ended in 1987
when he turned 18 years of age. See Fla. Stat. Ann. sec.
1.01(13) (West 1998). He was then emancipated under Florida law,
see Cronebaugh v. Van Dyke, 415 So. 2d 738, 741 (Fla. Dist. Ct.
App. 1982), and neither parent had custody, so that section
152(e)(1) is inapplicable for 1988 through 1990. See Kaechele v.
Commissioner, T.C. Memo. 1992-457 (finding that neither parent
had "custody" of their children within the meaning of section
152(e)(1) since the daughters had reached the age of majority and
were considered emancipated under Ohio law).
To show that Zachary was her dependent for the years in
question, petitioner must prove that, for those years, she
provided over half of his support. See sec. 152(a)(1); Rule
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