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Discussion
1. Dependency Exemptions
Section 151(c) allows a taxpayer, subject to certain
requirements, a deduction for a personal exemption for each of
the taxpayer's dependents as defined in section 152. A daughter
or a granddaughter of a taxpayer over half of whose support, for
the calendar year in which the taxable year of the taxpayer
begins, is provided by the taxpayer qualifies as a dependent.
Sec. 152(a)(1).
Section 1.152-1(a)(2)(i), Income Tax Regs., provides that in
determining whether an individual received over half of his or
her support from the taxpayer, "there shall be taken into account
the amount of support received from the taxpayer as compared to
the entire amount of support which the individual received from
all sources, including support which the individual himself
supplied." In Blanco v. Commissioner, 56 T.C. 512, 514-515
(1971), this Court held that, in establishing that more than one-
half of a dependent's support has been provided, a prerequisite
to such a showing is the demonstration by competent evidence of
the total amount of the dependent's support from all sources for
that year. If the amount of total support is not established and
cannot be reasonably inferred from competent evidence available
to the Court, it is not possible to conclude that the taxpayer
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