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purposes of section 152(a)(9), it is not necessary that the
dependent be related to the taxpayer but it is necessary that the
taxpayer both maintain and occupy the household. Sec. 1.152-
1(b), Income Tax Regs.
The term “support” includes food, shelter, clothing, medical
and dental care, education, and the like. Sec. 1.152-1(a)(2)(i),
Income Tax Regs. The total amount of support for each claimed
dependent furnished by all sources during the year in issue must
be established by competent evidence. Blanco v. Commissioner, 56
T.C. 512, 514 (1971); sec. 1.152-1(a)(1), Income Tax Regs. The
amount of support that the claimed dependent received from the
taxpayer is compared to the total amount of support the claimed
dependent received from all sources. Sec. 1.152-1(a)(2)(i),
Income Tax Regs.
Petitioner testified that Oumou and Mariam not only lived in
his apartment from shortly after the time that each was born
through the end of 1999, but also that he paid for all of their
food, clothing, and medical needs, and that he paid a major
portion of the rent for the apartment. The record, however, does
not support petitioner’s testimony, and we need not accept it.
Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).
We are not convinced that either Oumou’s or Mariam’s
principal place of abode during 1999 was petitioner’s apartment.
There is no documentary evidence supporting petitioner’s position
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