Tam N. Huynh - Page 11




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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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