Eliseo Argomaniz - Page 5




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          individual over half of whose support in the taxable year was               
          received from the taxpayer and whose principal place of abode for           
          the taxable year is the home of the taxpayer and is a member of             
          the taxpayer's household.  Sec. 152(a)(9).  In determining                  
          whether or not an individual received over half of his or her               
          support from the taxpayer, there shall be taken into account the            
          amount of support received from the taxpayer as compared to the             
          entire amount of support which the individual received from all             
          sources, including support which the individual himself or                  
          herself supplied.  Sec. 1.152-1(a)(2)(i), Income Tax Regs.                  
          Support includes food, shelter, clothing, medical and dental                
          care, education, and the like.  Sec. 1.152-1(a)(2)(i), Income Tax           
          Regs.                                                                       
               To establish that petitioner provided more than one-half of            
          the claimed dependents' support, he must first show by competent            
          evidence the total amount of support furnished by all sources for           
          the year in issue.  Blanco v. Commissioner, 56 T.C. 512, 514                
          (1971).  Petitioner has not offered competent evidence of the               
          total amount of support provided for each of the claimed                    
          dependents in 1998.  Aside from his testimony, petitioner                   
          presented no evidence to corroborate or substantiate any of the             
          claimed support expenses, such as rent, or that these expenses              
          were indeed paid by petitioner.  In fact, based on petitioner's             
          testimony, it appears that most of the family's expenses were               





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