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sec. 152(e) and the regulations concerning that section are
inapplicable where both parents combined do not provide more than
one-half the child’s total support during the year in question.
In applying the support test, we evaluate the amount of
support furnished by the taxpayer (or the taxpayer and his former
wife in the case of divorced parents) as compared to the total
amount of support received by the claimed dependent from all
sources. Turecamo v. Commissioner, 554 F.2d 564, 569 (2d Cir.
1977), affg. 64 T.C. 720 (1975); sec. 1.152-1(a)(2)(i), Income
Tax Regs. The taxpayer must initially demonstrate, by competent
evidence, the total amount of support furnished by all sources
for the taxable year at issue. Blanco v. Commissioner, 56 T.C.
512, 514 (1971). Otherwise, the taxpayer cannot be said to have
established that he provided more than one-half of the support
for the claimed dependent. Id. at 514-515.
Support provided by a third party, such as a Federal or
State agency, is not considered support furnished by the
taxpayer. See, e.g., Gulvin v. Commissioner, 644 F.2d 2 (5th
Cir. 1981), affg. T.C. Memo. 1980-111; Lutter v. Commissioner, 61
T.C. 685 (1974), affd. 514 F.2d 1095 (7th Cir. 1975); Williams v.
Commissioner, T.C. Memo. 1996-126, affd. without published
opinion 119 F.3d 10 (11th Cir. 1997).
Petitioner reported total income of $10,698 on his 1998
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