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claimed dependent. 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.
While petitioner provided some aid to her father and
brother, we cannot conclude that petitioner provided more than
one-half of the support for either of them. We are unsure as to
the total amount of support her father and brother received from
all sources. The record is also silent as to the amount of
support each received from petitioner. Therefore, respondent’s
determination is sustained.
2. Medical Expenses
A taxpayer may deduct expenses incurred for medical and
dental expenses of a dependent (as defined in section 152) to the
extent that the expenses exceed 7.5 percent of the taxpayer’s
adjusted gross income. Sec. 213(a).
Petitioner deducted medical expenses of $18,005 relating to
the medical care of her father. For the reasons set forth above,
petitioner’s father does not qualify as her dependent pursuant to
section 152. Petitioner is not entitled to deduct her father’s
medical expenses. Even if petitioner’s father qualified as a
dependent, petitioner failed to satisfy the substantiation
requirements of section 1.213-1(h), Income Tax Regs.
Accordingly, we sustain respondent’s determination.
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