- 3 - 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 claimedPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011