Helen Hubbard - Page 6




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          support cost expended for her grandmother in 1999 and failed to             
          establish that she provided over half of that amount.                       
               Petitioner also claims that she gave her daughter money                
          while her daughter was ill.  Petitioner, however, concedes that             
          her daughter received Social Security benefits and child-support            
          payments.  Petitioner failed to substantiate the total amount               
          expended on behalf of her daughter for support during 1999 and              
          that she provided over half of that amount.                                 
               Respondent argues that petitioner failed to substantiate her           
          claims with records, receipts, or any other evidence of                     
          expenditures.  Petitioner has offered no evidence of the total              
          support furnished for her grandmother or daughter and has                   
          provided no evidence of her own contributions of support.  The              
          Court cannot conclude that petitioner provided more than one-half           
          of either of their support.  The Court thus holds that petitioner           
          is not entitled to the dependency exemption deductions for her              
          grandmother and daughter.                                                   
               Section 152(e), support test in case of divorced parents,              
          etc., provides a special rule for children of separated parents.            
          Section 152(e)(1) provides that, if the child receives over half            
          of his support from his parents and he is in the custody of one             
          or both of his parents for more than half of the year, then the             
          child is treated as receiving over half of his support from the             
          custodial parent.  Because Ms. Saeed and her children’s father              






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