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satisfy the definition of a “dependent” within the meaning of
section 152(a) (the relationship or member of household
requirement); and (3) petitioner must furnish more than half of
the dependent’s total support (the support requirement). See
secs. 151(c)(1)(A); 152(a). All requirements must be satisfied
for each individual claimed by petitioner.
Each claimed individual satisfies the definitional
requirement of “dependent” within the meaning of section 152(a)
under the relationship test (as nieces, nephews, or brothers) or
the principal place of abode requirement (i.e., Reginald for
1997). Therefore, the next issue is whether petitioner furnished
more than one-half of each dependent’s total support.
The term “support” includes food, shelter, clothing, medical
and dental care, education, etc. Sec. 1.152-1(a)(2)(i), Income
Tax Regs. The amount of total support may be reasonably inferred
from competent evidence. See Stafford v. Commissioner, 46 T.C.
515, 518 (1966). However, where the amount of total support of a
dependent during the taxable year is not shown and cannot be
reasonably inferred from competent evidence, then it is not
possible to conclude that the taxpayer has contributed more than
one-half. See Blanco v. Commissioner, 56 T.C. 512, 515 (1971);
Fitzner v. Commissioner, 31 T.C. 1252, 1255 (1959).
Although we find petitioner’s testimony credible that she
contributed to each claimed individual’s support, the record
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