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As the noncustodial parent, petitioner is allowed to claim
the children as dependents only if he meets one of three
statutory exceptions under section 152(e). The noncustodial
parent can claim the dependency exemption deduction if: (1) The
custodial parent releases claim to the exemption for the year;
(2) a multiple-support agreement is in effect; or (3) the decree
of divorce was executed prior to 1985, the decree expressly
provides that the noncustodial parent is entitled to the
deduction, and the noncustodial parent provides at least $600 for
the support of the child. Sec. 152(e)(2), (3), and (4); sec.
1.152-4T, Temporary Income Tax Regs., 48 Fed. Reg. 34459 (Aug.
31, 1984).
After reviewing the record, it is clear that petitioner does
not satisfy any of the exceptions under section 152(e).
Therefore, we sustain respondent’s determination denying
dependency exemptions as to the children.
In order to claim Ms. Williams as a dependent, petitioner
must show by competent evidence: (1) The total support provided
for the individual claimed, 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 an individual during the taxable year is not
shown, and cannot be reasonably inferred from competent evidence,
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