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returns. Similar to mortgage interest deductions, real estate
taxes are deductible under section 164(a) only by the person on
whom the liability is imposed. Magruder v. Supplee, 316 U.S.
394, 398 (1942); Cramer v. Commissioner, 55 T.C. 1125, 1130
(1971); Manning v. Commissioner, T.C. Memo. 1993-127. Because we
found above that petitioner was not the legal, equitable, or
beneficial owner of the LA property, he is also not entitled to
Schedule A deductions for real estate taxes paid thereon.
Respondent is sustained on this issue.
Dependency Exemption
Section 151(c) allows a taxpayer to deduct an annual
exemption amount for each dependent of the taxpayer. As relevant
here, a “dependent” is defined in section 152(a) as an individual
“over half of whose support, for the calendar year in which the
taxable year of the taxpayer begins, was received from the
taxpayer”. In order to prevail, petitioner must show by
competent evidence: (1) The total support provided for each
individual claimed, and (2) that he provided more than half of
such total support. The amount of total support may be
reasonably inferred from competent evidence. Stafford v.
Commissioner, 46 T.C. 515, 518 (1966). However, where the amount
of total support of an individual 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
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