Tiffany Paramore - Page 5




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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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