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For purposes of the dependency exemption deduction, support
is defined to include “food, shelter, clothing, medical and
dental care, education, and the like.” Sec. 1.152-1(a)(2)(i),
Income Tax Regs. Respondent points out that the record does not
reveal the exact amount of public assistance that Delores
Hamilton received on behalf of the children during the years in
issue. Therefore, according to respondent, it cannot be
determined whether petitioner and Delores Hamilton provided over
one half of the children’s support. We disagree. Although the
record is not as complete as we would like, we are satisfied that
the amount of child support petitioner paid, plus the value of
the housing that he provided for the children, plus the cost of
the children’s medical insurance, plus the incidental expenses he
incurred for food, clothing, and entertainment while the children
resided at his house, plus whatever support the children received
from Delores Hamilton from nonpublic sources, amounted to more
than one-half of the children’s total support during the years in
issue.
We have considered respondent’s other argument in support of
the disallowances of the dependency exemption deductions here in
dispute and find the argument to have no application under the
circumstances of this case. Therefore, petitioner is entitled to
a dependency exemption deduction for each of his children for
each year in issue.
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Last modified: May 25, 2011