Steven Genoris Wilkerson - Page 5




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          month.  Petitioner contends he paid $300 per month for his part             
          of the rent and paid one of the utility bills each month,                   
          including some amount for food.  The remainder was paid by his              
          mother.  Christopher did not live with petitioner on a full-time            
          basis, which petitioner acknowledges.  Petitioner testified that            
          Christopher was "in and out of the house" throughout the year and           
          estimated that Christopher lived with him, on this basis, for at            
          least 6 months of the year.  No documentary evidence was                    
          submitted establishing the exact amount of time Christopher lived           
          with petitioner during 2000, nor was any evidence presented to              
          establish the amount of support petitioner provided to                      
          Christopher during the year, as well as the amount of support               
          provided by others, including petitioner's mother and the child's           
          mother, and any other outside sources.                                      
               Section 151(c) allows taxpayers to deduct an annual                    
          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 taxable year in which such individuals are              
          claimed as dependents.  Eligible individuals who may be claimed             
          as dependents include, among others, a son or stepson of the                
          taxpayer.  See sec. 152(a)(1) and (2).  If a claimed dependent is           
          not within the category of relationships listed in section                  
          152(a)(1) through (8), section 152(a)(9) provides generally that            





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