Princess Stephan Obriot - Page 7




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          and $396 for 1997 and 1998, respectively.  Petitioner gave the              
          Stephans money each month for utilities.  The Stephans paid the             
          utility bills from a combination of petitioner’s contributions              
          and their own funds.  We are satisfied that the amount expended             
          by petitioner for utilities exceeded Ayla’s allocable share.                
               Petitioner purchased all of the groceries for herself and              
          Ayla.  The total amount of support for Ayla includes one-half of            
          the amount spent by petitioner on food.  We conclude that the               
          amount expended for Ayla’s support was $1,800 in each of 1997 and           
          1998.                                                                       
               Petitioner paid for all of Ayla’s additional expenses                  
          including Ayla’s medical expenses that were not covered by                  
          Medicare, dental care, and clothes.  The amounts petitioner spent           
          on these items are included in the amount of support for Ayla.              
          The Medicare benefits that Ayla received are not included in the            
          entire amount of her support.  Turecamo v. Commissioner, 554 F.2d           
          564 (2d Cir. 1977), affg. 64 T.C. 720 (1975); Rev. Rul. 79-173,             
          1979-1 C.B. 86.  We conclude that the amount of additional                  
          expenses for Ayla was $800 in each of 1997 and 1998.                        
               Petitioner paid for Ayla to attend two day care centers, one           
          of which was subsidized.  The amounts spent on Ayla’s day care              
          centers, including the subsidies, are included in the entire                
          amount of Ayla’s support; however, the subsidies are not treated            
          as contributions made by petitioner.  Cf. Donner v. Commissioner,           






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