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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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Last modified: May 25, 2011