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C.B. 392, 395. For purposes of section 151(c), gross income does
not include the amount of Social Security benefits excluded from
gross income under section 86(a). See Carter v. Commissioner,
T.C. Memo. 1998-243, affd. without published opinion 187 F.3d 640
(8th Cir. 1999). However, in determining the total amount
contributed for the claimed dependent’s support, and determining
whether a taxpayer contributed more than half the support of
another, amounts of support paid by Social Security benefits are
considered. See id.; sec. 1.152-1(a)(2)(ii), Income Tax Regs.
Medicare benefits are not considered in determining the total
amount contributed for the claimed dependent’s support. Turecamo
v. Commissioner, 64 T.C. 720 (1975), affd. 554 F.2d 564 (2d Cir.
1977).
Because Social Security benefits are included in the
computation of total support, petitioner, at a minimum, must show
that during 1997 he contributed more than $8,310 toward the
support of Mrs. Morgan. Additionally, petitioner must show the
total amount of her support furnished by all sources for the
year. Blanco v. Commissioner, 56 T.C. 512, 514 (1971); Jeter v.
Commissioner, T.C. Memo. 2001-223, affd. per curiam without
published opinion ___ F.3d ___ (4th Cir., Feb. 6, 2002); sec.
1.152-1(a)(2)(i), Income Tax Regs. The term “support” includes,
among other things, food, shelter, clothing, and medical care.
Sec. 1.152-1(a)(2)(i), Income Tax Regs. The amount of total
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