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