Gabriel M. Daya, et al. - Page 21




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          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 provided            






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