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filing status was single, not head of household, and also
disallowed the earned income credit.
Dependency Exemption
Section 151(c) allows a taxpayer to deduct an annual
exemption amount for each dependent of the taxpayer. A
“dependent” is defined in section 152(a) as an individual “over
half of whose support, for the calendar year in which the taxable
year of the taxpayer begins, was received from the taxpayer (or
is treated under subsection (c) or (e) as received from the
taxpayer)”. In order to prevail, petitioner must show by
competent evidence: (1) The total support provided for each
child, and (2) that he provided more than half of such total
support. The amount of total support may be reasonably inferred
from competent evidence. See Stafford v. Commissioner, 46 T.C.
515, 518 (1966). However, where the amount of total support of a
child during the taxable year is not shown, and cannot be
reasonably inferred from competent evidence, then it is not
possible to conclude that the taxpayer has contributed more than
one-half. See Blanco v. Commissioner, 56 T.C. 512, 515 (1971);
Fitzner v. Commissioner, 31 T.C. 1252, 1255 (1959).
Although we find petitioner’s testimony credible as to the
amount he contributed to the children’s support, the record based
solely on his contributions is incomplete. Petitioner was unable
to reconstruct the dollar amount of the total support for the
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