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support during 1999, even if she contributed $1,300 for his
support that year to pay for Brandon's incidental needs. The
Court rejects petitioner's contention that, because Brandon
qualified for and received special education at the prison,
petitioner was entitled to claim the dependency exemption
deduction for him. Section 152 and applicable regulations have
no provision that would qualify the beneficiaries of such
assistance as dependents under section 152. It is quite evident
from the record that Brandon's total support for 1999 was not
established, and that factor alone is sufficient to disallow
petitioner's entitlement to the dependency exemption deduction.
It is also evident that the support provided to Brandon by the
State prison system where he was incarcerated far exceeded the
monetary amounts provided by petitioner. Respondent, therefore,
is sustained on this issue.
The second issue is whether Brandon, during 1999, was a
qualifying child with regard to petitioner for purposes of the
earned income credit under section 32(a).
Section 32(a) provides for an earned income credit in the
case of an eligible individual. Section 32(c)(1)(A), in
pertinent part, defines an "eligible individual" as an individual
who has a qualifying child for the taxable year. Sec.
32(c)(1)(A)(i). A qualifying child is one who satisfies a
relationship test, a residency test, an age test, and an
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