Sean E. Batson - Page 3

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                  Section 151(c) allows taxpayers to deduct an annual                                  
            exemption amount for each dependent as defined in section 152.                             
            Under section 152(a), the term "dependent" means certain                                   
            individuals over half of whose support was received from the                               
            taxpayer during the taxable year in which such individuals are                             
            claimed as dependents.  Eligible individuals who may be claimed                            
            as dependents include, among others, a son or daughter of the                              
            taxpayer.  See sec. 152(a)(1).                                                             
                  Section 1.152-1(a)(2)(i), Income Tax Regs., provides that,                           
            in determining whether an individual received over half of his                             
            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                                    
            supplied."  In Blanco v. Commissioner, 56 T.C. 512, 514-515                                
            (1971), this Court held that, in establishing that more than one-                          
            half of a dependent's support has been provided, a prerequisite                            
            to such a showing is the demonstration by competent evidence of                            
            the total amount of the dependent's support from all sources for                           
            that year.  If the amount of total support is not established and                          
            cannot be reasonably inferred from competent evidence available                            
            to the Court, it is not possible to conclude that the taxpayer                             
            claiming the exemption provided more than one-half of the support                          
            of the claimed dependent.                                                                  

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Last modified: May 25, 2011