George H. Richards - Page 8

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          exemption deductions and head-of-household filing status.  These            
          are new matters for which respondent bears the burden of proof.             
               Issue 1.  Dependency Exemption Deductions                              
               A dependent is defined as an individual, such as a son or              
          daughter of the taxpayer, over half of whose support for the                
          calendar year was received from the taxpayer.  Sec. 152(a)(1);              
          sec. 1.152-1(a), Income Tax Regs.  As relevant here, the child              
          must not have attained the age of 19 by the close of the calendar           
          year.  Sec. 151(c)(1)(B)(i).                                                
               Support includes food, shelter, clothing, medical and dental           
          care, education, and the like.  Sec. 1.152-1(a)(2)(i), Income Tax           
          Regs.  The total amount of support for each claimed dependent               
          furnished by all sources during the year in issue must be                   
          established by competent evidence.  Blanco v. Commissioner, 56              
          T.C. 512, 514 (1971).  The amount of support that the claimed               
          dependent received from the taxpayer is compared to the total               
          amount of support the claimed dependent received from all                   
          sources.  Sec. 1.152-1(a)(2)(i), Income Tax Regs.  It must also             
          be established that the taxpayer provided more than one-half of             
          the total support for each claimed dependent.  Secs. 151 and 152;           
          sec. 1.152-1(a)(1), Income Tax Regs.                                        
               In the case of a child who receives over half of his support           
          from parents who are divorced or legally separated under a decree           

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