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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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