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not have a qualifying child for the earned income tax credit.
Respondent also changed petitioner’s filing status to single.
Discussion
1. Dependency Exemption Deduction
A taxpayer is permitted to claim as a deduction an exemption
for certain dependents. See sec. 151(a), (c)(1). A taxpayer’s
son qualifies as a dependent so long as the taxpayer provided
more than half of the support to the dependent. See sec.
152(a)(1); sec. 1.152-1(a)(1), Income Tax Regs.
The level of support is determined by the support test, in
which the total amount of support from all sources is compared
with the amount of support actually provided by a taxpayer. The
taxpayer must establish, by competent evidence, the total amount
of the support furnished by all sources for the taxable year at
issue. See Turay v. Commissioner, T.C. Memo. 1999-315; Keegan v.
Commissioner, T.C. Memo. 1997-511; sec. 1.152-1(a)(2)(i), Income
Tax Regs. If the total amount of support is not established,
then it is generally not possible to conclude that the taxpayer
provided more than half of the support to the claimed dependent.
See Blanco v. Commissioner, 56 T.C. 512, 514-515 (1971); Batson
v. Commissioner, T.C. Memo. 2000-172; Butler v. Commissioner,
T.C. Memo. 1998-355; Smith v. Commissioner, T.C. Memo. 1997-544.
Support includes such items as food, shelter, medical
expenses, and clothing. See sec. 1.152-1(a)(2)(i), Income Tax
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