- 6 -
Trowbridge v. Commissioner, 268 F.2d 208 (9th Cir. 1959), affg.
30 T.C. 879 (1958); McMillan v. Commissioner, 31 T.C. 1143, 1145-
1146 (1959); Rodenbaugh v. Commissioner, T.C. Memo. 1981-593,
sec. 1.152-1(b), Income Tax Regs.
If an individual qualifies as the taxpayer's dependent by
meeting the above requirements, a taxpayer is entitled to a
dependency exemption deduction for that dependent if (1) the
individual's gross income is less than the exemption amount
($2,500 in 1995; $2,550 in 1996), or (2) if the dependent is a
child of the taxpayer, the child has not attained the age of 19
or is a student who has not attained the age of 24 at the close
of the calendar year. See sec. 151(c)(1).
Petitioner testified that he provided complete support to
each of the claimed dependents for the years in issue. To
determine the amount of support provided by a taxpayer to a
dependent, we must evaluate the amount of support furnished by
the taxpayer as compared to the total amount of support received
by the claimed dependent from all sources. See Turecamo v.
Commissioner, 554 F.2d 564, 569 (2d Cir. 1977), affg. 64 T.C. 720
(1975); sec. 1.152-1(a)(2)(i), Income Tax Regs. The total amount
of support received by the claimed dependent includes any amount
which that individual has contributed for his or her own support.
See Blanco v. Commissioner, 56 T.C. 512, 514-515 (1971); Seraydar
v. Commissioner, 50 T.C. 756, 760 (1968); Stafford v.
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