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Section 151 allows a taxpayer to deduct an annual exemption
amount for each dependent, as defined in section 152. Under
section 152(a), the term dependent, in pertinent part, means a
son, a brother, or the father or mother of the taxpayer over half
of whose support was received from the taxpayer. Sec. 152(a)(1),
(3), (4).
In determining whether or not 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 or herself supplied. Sec. 1.152-1(a)(2)(i),
Income Tax Regs. Support includes food, shelter, clothing,
medical and dental care, education, and the like. Sec. 1.152-
1(a)(2)(i), Income Tax Regs.
After a review of the record, we find that petitioner has
not established that she is entitled to the dependency exemptions
claimed for Antonio, her brother, and her parents in 1993.
To establish that petitioner provided more than one-half of
the claimed dependents' support, she must first show by competent
evidence the total amount of support furnished by all sources for
the year in issue. Blanco v. Commissioner, 56 T.C. 512, 514
(1971). Petitioner has not offered competent evidence of the
total amount of support provided for each of the claimed
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Last modified: May 25, 2011