- 21 - received an equal part of the contributions as part of his support. See De La Garza v. Commissioner, 46 T.C. 446 (1966), affd. per curiam 378 F.2d 32 (5th Cir. 1967). Similarly, when an individual outside the household not sharing in the common fund contributes funds to the support of the household, that individual’s contributions are allocated equally to each member of the household. See Cogan v. Commissioner, T.C. Memo. 1971-251. Any “amount contributed to a common family fund by a particular member of the household is deemed to have been supplied in full for his support when such amount is less than his aliquot share of the entire fund.” De La Garza v. Commissioner, supra at 449. On brief petitioners state that sums from various bank accounts can be identified as payments for items constituting expenditures for support within the meaning set forth in section 1.152-1(a)(2)(i), Income Tax Regs. Petitioners, however, have not identified those payments which they believe constitute support, and we are unable to determine how they computed their support figures, except that it is clear they included mortgage interest and personal property tax payments on the Foster City residence in their calculations. Gabriel has failed to establish the total amount expended on Mahmoud’s support from all sources in 1995 and 1996. He likewise has failed to establish his own contributions toward his father’s support. Gabriel’s only testimony regarding support he providedPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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