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issue to show the value of the Mahmoud Daya family’s lodging. The
value of a claimed dependent’s lodging must be included as part of
his total support; it is well settled, however, that the proper
measure for valuing lodging for purposes of determining support is
the fair rental value of the premises allocable to the claimed
dependent and not the actual mortgage payments and property taxes
paid for maintaining the household. See Pierce v. Commissioner,
66 T.C. 840, 849 (1976); Blarek v. Commissioner, 23 T.C. 1037,
1039 (1955); Keegan v. Commissioner, T.C. Memo. 1997-511; Pierce
v. Commissioner, T.C. Memo. 1981-254; Gilliam v. Commissioner,
T.C. Memo. 1969-188, affd. per curiam 429 F.2d 570 (4th Cir.
1970); Tourte v. Commissioner, T.C. Memo. 1969-143; Sumner v.
Commissioner, T.C. Memo. 1969-156; Coary v. Commissioner, T.C.
Memo. 1969-25; sec. 1.152-1(a)(2)(i), Income Tax Regs.
Petitioners have not provided any evidence from which we could
conclude that the mortgage payments and property taxes are in any
way related to the fair rental value of the Foster City residence.
See Coary v. Commissioner, supra. Without evidence of the fair
rental value of the residence, Gabriel cannot establish Mahmoud’s
total support. See Sumner v. Commissioner, supra; Coary v.
Commissioner, supra.
Petitioners assume they should be credited with supplying the
Mahmoud Daya family’s lodging during the years in issue, but it is
the owner of the premises who is to be credited with providing the
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