- 4 - 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 totalPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011