Domingo Perez - Page 4

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          "dependent" also means a stepfather or stepmother of the                    
          taxpayer.  Sec. 152(a)(5).                                                  
               To meet the support test under section 152(a), a taxpayer              
          must show--                                                                 
               (1) the total amounts received by the dependent from                   
               all sources; (2) the amounts actually applied for the                  
               support of the dependent; (3) the sources which                        
               contributed to the total support costs expended on                     
               behalf of the dependent; and (4) that the taxpayer                     
               provided over half of the total expenditures for the                   
               dependent's support. * * * [Barnes v. Commissioner,                    
               T.C. Memo. 1986-585; fn. refs. omitted.]                               
          See also Archer v. Commissioner, 73 T.C. 963, 967 (1980); sec.              
          1.152-1(a)(2)(i), Income Tax Regs.  If the total amount of                  
          support is not shown and cannot be reasonably inferred from the             
          competent evidence available, it is impossible to conclude that             
          petitioner furnished more than one-half.  Blanco v. Commissioner,           
          56 T.C. 512, 514-515 (1971).                                                
               We do not have sufficient information in this case as to the           
          total amount of support provided to Tirone and Leslie Ortiz from            
          all sources.  Thus, we are uncertain as to whether petitioner               
          provided more than one-half the total support for either of the             
          claimed dependents.  Respondent is sustained on this issue.                 
               In order to qualify for head-of-household filing status,               
          petitioner must satisfy the requirements of section 2(b).                   
          Pursuant to that section, and as relevant herein, an individual             
          qualifies as a head of household if the individual is not married           
          at the close of the taxable year and maintains as his home a                




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