Princess Stephan Obriot - Page 5




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          The term “support” includes food, shelter, clothing, medical care           
          and dental care, education, child care, and the like.  Lustig v.            
          Commissioner, 274 F.2d 448 (9th Cir. 1960) (allowing child care             
          expense to be factored into determination of whether taxpayer               
          contributed more than one-half of the support of a claimed                  
          dependent), affg. 30 T.C. 926 (1958); sec. 1.152-1(a)(2)(i),                
          Income Tax Regs.                                                            
               To determine whether a taxpayer has provided more than one-            
          half of the support of an individual, the entire amount of                  
          support which the individual received from the taxpayer is                  
          compared to the entire amount of support which the individual               
          received from all sources.  Sec. 1.152-1(a)(2)(i), Income Tax               
          Regs.                                                                       
               We thus compare the entire amount expended for Ayla’s                  
          support to the amount provided by petitioner.  From a review of             
          the record, we conclude that the amounts expended as support for            
          Ayla and the amounts provided by petitioner are as follows:                 
                                        1997                                          
                         Total Support for Ayla   Support From Petitioner             
          Rent                $1,425                   $0                             
          Utilities           348                      348                            
          Food                1,800                    1,800                          
          Clothing,                                                                   
          medical, etc.            800                 800                            
          Child care             3,900                  1,195                         
          Total               8,273                    4,143                          







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