Helen Hubbard - Page 5




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               Section 151(c)(1) allows a taxpayer to claim an exemption              
          deduction for each qualifying dependent as defined in section               
          152.  As relevant here, section 152(a)(1) defines a “dependent”             
          to mean a taxpayer's daughter, grandchildren, or grandparent who            
          received or is treated under section 152(e) as having received              
          over half of his or her support from the taxpayer.  To qualify              
          for a dependency exemption deduction, a taxpayer must establish             
          the total support cost expended on behalf of a claimed dependent            
          from all sources for the year and demonstrate that she provided             
          over half of this amount.  See Archer v. Commissioner, 73 T.C.              
          963, 967 (1980); Blanco v. Commissioner, 56 T.C. 512, 514-515               
          (1971); sec. 1.152-1(a)(2)(i), Income Tax Regs.                             
               Petitioner argues that her grandmother and daughter meet the           
          relationship, gross income, and support tests provided in the               
          Internal Revenue Code and in the “RULES AS SET FORTH IN 1999 CAT.           
          NO. 12086Y and Chapter 3 of Personal Exemptions and Dependents”.            
          Her position is that her relatives do not need to live with her             
          to qualify for the deduction.                                               
               Petitioner testified that her grandmother’s only outside               
          source of income was Social Security.  Specifically, petitioner             
          argues that her grandmother qualifies as a dependent because she            
          “lived” with petitioner under the temporary absence explanation             
          provided in “Chapter 3 page 23".  We need not evaluate the merits           
          of petitioner’s argument because she failed to show the total               






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