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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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