- 7 - exemption deductions and head-of-household filing status. These are new matters for which respondent bears the burden of proof. Id. 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 decreePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011