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claimed dependents furnished by all sources during the year in
issue must be established by competent evidence. Blanco v.
Commissioner, 56 T.C. 512, 514 (1971). The amount of support
that the claimed dependent received from the taxpayer is compared
to the entire amount of support the individual received from all
sources. Sec. 1.152-1(a)(2)(i), Income Tax Regs.
In the case of a child of divorced parents, if a child
receives over half of his support during the calendar year from
parents who are divorced, and such child is in the custody of one
or both of his parents for more than one-half of the calendar
year, then such child shall be treated as receiving over half of
his support during the calendar year from the parent having
custody for a greater portion of the calendar year (referred to
as the “custodial parent”). Sec. 152(e)(1).
As discussed, petitioner paid for most of the expenses for
Joshua and Joseph during 2000, including housing, food, and
school expenses. Ms. Jackson testified that she paid for clothes
and food for Joshua and Joseph on occasion, but she did not
otherwise provide for their support on a regular basis or pay
child support. We conclude that petitioner and Ms. Jackson
together provided over one-half of the support of Joshua and
Joseph.
Ms. Jackson also testified that Joshua and Joseph stayed
with her at her home in Alexandria occasionally on weekends but
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