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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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