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competent evidence available to the Court, it is not possible to
conclude that the taxpayer claiming the exemption provided more
than one-half of the support of the claimed dependent. See Blanco
v. Commissioner, supra.
The claimed dependent’s contributions toward his or her own
support are part of the total support computation and include
“income which is ordinarily excludable from gross income, such as
benefits received under the Social Security Act.” Sec. 1.152-
(1)(a)(2)(ii), Income Tax Regs. Only the amount of such income
actually spent on the individual’s support is considered in
determining support for purposes of the dependency exemption. See
Carter v. Commissioner, 55 T.C. 109 (1970).
“The term ‘support’ includes food, shelter, clothing, medical
and dental care, education, and the like.” Sec. 1.152-1(a)(2)(i),
Income Tax Regs. Although the amount of an item of support is
usually its cost, where lodging is furnished to an individual, the
amount of support is the fair market value of such lodging. See
id.
If several members of a household contribute toward expenses
which are equally applicable to the support of each member of the
household and there is no evidence of actual support for
individual members of a household, the contributing members are
presumed to have pooled their contributions to support the
household, and each member of the household is considered to have
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