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taxpayer’s parents and siblings “over half of whose support, for
the calendar year * * * was received from the taxpayer”. Sec.
152(a)(3)and (4). “The term ‘support’ includes food, shelter,
clothing, medical and dental care, education, and the like.”
Sec. 1.152-1(a)(2)(i), Income Tax Regs.
During 1996, petitioner generously contributed towards the
support of the household of which she was a member. She paid
some of the utilities, bought food, and purchased clothing for
her family members. Nevertheless, taking into account the modest
amount of her income, the amount of the Federal income tax refund
she received in 1996, the amount of the mortgage payments made
by her father, and the amount of public assistance petitioner’s
mother received on behalf of herself and her children, we
are not convinced from petitioner’s generalized testimony that
she contributed over one-half of the support for any of the
individuals to whom the dependency exemption deductions here in
dispute relate. Consequently, petitioner is not entitled to a
dependency exemption deduction for any of her siblings or her
mother, and respondent’s determinations in this regard are
sustained.
2. Filing Status
Petitioner filed her 1996 return as a head of household.
Under the circumstances, because petitioner is not entitled to
a dependency exemption deduction for any of her siblings or her
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Last modified: May 25, 2011