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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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