John S. Turay - Page 6




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          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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