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The level of support is determined by the support test, in
which the total amount of support from all sources is compared
with the amount of support actually provided by a taxpayer. The
taxpayer must initially demonstrate, by competent evidence, the
total amount of the support furnished by all sources for the
taxable years at issue. See Turay v. Commissioner, T.C. Memo.
1999-315; Keegan v. Commissioner, T.C. Memo. 1997-511; sec.
1.152-1(a)(2)(i), Income Tax Regs. If the total amount of
support is not established, then it is generally not possible to
conclude that the taxpayer provided more than half of the support
to the claimed dependents. See Blanco v. Commissioner, 56 T.C.
512, 514-515 (1971); Batson v. Commissioner, T.C. Memo. 2000-172;
Butler v. Commissioner, T.C. Memo. 1998-355; Smith v.
Commissioner, T.C. Memo. 1997-544.
From a review of this record, we cannot conclude that either
petitioner provided more than one-half of the support for any of
the claimed dependents at issue. We are unsure as to the total
amount of support each dependent received from all sources. The
record is also silent as to the amount of support each dependent
received from either of petitioners. Therefore, respondent’s
determination is sustained.
2. Earned Income Credit
Section 32(a) permits an “eligible individual” to claim an
earned income credit against the individual’s income tax
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