Matthew K. Morgan - Page 6




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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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