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The first issue for decision is whether petitioner is
entitled to dependency exemption deductions for his two sons.
Section 151(c)(1) allows a taxpayer to deduct an exemption amount
for each dependent as defined in section 152. Under section
152(a), the term “dependent” means certain individuals over half
of whose support was received from the taxpayer during the
calendar year for which such individuals are claimed as
dependents. Support includes food, shelter, clothing, medical
and dental care, education, and the like. Sec. 1.152-1(a)(2)(i),
Income Tax Regs. Eligible individuals who may be claimed as
dependents include, among others, sons of the taxpayer. Sec.
152(a)(1).
In deciding whether an individual received over half of his
support from the taxpayer, we evaluate the amount of support
furnished by the taxpayer 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).
If the amount of total support is not established and cannot be
reasonably inferred from competent evidence available to the
Court, it is not possible to conclude that the taxpayer claiming
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Last modified: May 25, 2011