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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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