LaTanya Haywood - Page 3




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          the term "dependent" means certain individuals over half of whose           
          support was received from the taxpayer during the taxable year in           
          which such individuals are claimed as dependents.  Eligible                 
          individuals who may be claimed as dependents include, among                 
          others, a son or daughter of the taxpayer.  See sec. 152(a)(1).             
               Section 1.152-1(a)(2)(i), Income Tax Regs., provides that,             
          in determining whether an individual received over half of his              
          support from the taxpayer, "there shall be taken into account the           
          amount of support received from the taxpayer as compared to the             
          entire amount of support which the individual received from all             
          sources, including support which the individual himself                     
          supplied."  In Blanco v. Commissioner, 56 T.C. 512, 514-515                 
          (1971), this Court held that, in establishing that more than one-           
          half of a dependent's support has been provided, a prerequisite             
          to such a showing is the demonstration by competent evidence of             
          the total amount of the dependent's support from all sources for            
          that year.  If the amount of total support is not established and           
          cannot be reasonably inferred from competent evidence available             
          to the Court, it is not possible to conclude that the taxpayer              
          claiming the exemption provided more than one-half of the support           
          of the claimed dependent.                                                   
               Petitioner's son, Brandon R. Haywood (Brandon), was born on            
          August 12, 1978, and, thus, attained the age of 21 during 1999.             
          On April 15, 1995, Brandon was convicted in the State of Missouri           





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