Gabriel M. Daya, et al. - Page 19




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          provide more than half his father’s support in 1995 and 1996.               
               Petitioners suggest Federal tax law does not require                   
          taxpayers to show that expenditures of support were paid from               
          specific sources.  They argue that they contributed all the funds           
          that went into the household account, that most of the expenses of          
          supporting the Mahmoud Daya family were paid with funds from the            
          household account, and that neither Federal income tax law nor              
          logic prevents them from agreeing that Gabriel’s contributions              
          toward the support of the family be considered to be made on                
          behalf of his father and that Morhaf’s contributions be considered          
          on behalf of his mother.12  We disagree with petitioners’                   
          interpretation of both the facts and the law.                               
               To qualify for dependency exemption deductions, a taxpayer             
          must establish the total support costs expended on behalf of a              
          claimed dependent from all sources for the year, and the taxpayer           
          must demonstrate that he provided over half of this amount.  See            
          Archer v. Commissioner, 73 T.C. 963, 967 (1980); Turecamo v.                
          Commissioner, 554 F.2d 564, 569 (2d Cir. 1977), affg. 64 T.C. 720           
          (1975); Blanco v. Commissioner, 56 T.C. 512, 514-515 (1971); sec.           
          1.152-1(a)(2)(i), Income Tax Regs.  If the amount of total support          
          is not established and cannot be reasonably inferred from                   

               12 We note that neither Morhaf or Fuad filed a written                 
          declaration that he would not claim Mahmoud as a dependent in               
          1995 or 1996 in accordance with sec. 152(c)(4) such that we                 
          should consider whether Gabriel could be treated as having                  
          provided over half of Mahmoud’s support under the provisions of             
          sec. 152(c), Multiple Support Agreements.                                   




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