Randolph John Beale - Page 19




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            dependent for either year.  We therefore sustain respondent’s                              
            determination that petitioner is not entitled to an additional                             
            exemption for his spouse for taxable years 1994 and 1995.                                  
                  To claim additional exemptions for his stepdaughters,                                
            petitioner must prove that he provided more than one-half of                               
            their total support in 1994 and 1995.  See sec. 152(a)(2).  In                             
            applying the support test, we 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.  In                            
            other words, in order to establish that the taxpayer provided                              
            more than one-half of the claimed dependent’s support, the                                 
            taxpayer must first show, by competent evidence, the total amount                          
            of support received by the claimed dependent from all sources                              
            during the year in issue.  Otherwise, the taxpayer cannot be said                          
            to have established that he or she provided more than one-half of                          
            the support for the claimed dependent.  See, e.g., Blanco v.                               
            Commissioner, 56 T.C. 512, 514-515 (1971); Seraydar v.                                     
            Commissioner, 50 T.C. 756, 760 (1968); Stafford v. Commissioner,                           
            46 T.C. 515, 518 (1966).                                                                   
                  Petitioner presented no evidence that he provided more than                          
            one-half of the support for his stepdaughters during taxable                               
            years 1994 and 1995.  Accordingly, petitioner's claim to                                   






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