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an individual may nevertheless qualify as a dependent if such
individual, for the entire taxable year, had "as his principal
place of abode the home of the taxpayer and is a member of the
taxpayer's household." Sec. 152(a)(9); sec. 1.152-1(b), Income
Tax Regs. Also, a foster child is treated as a child of the
taxpayer if the child satisfies the requirements of section
152(a)(9). Sec. 152(b)(2).
Section 1.152-1(a)(2)(i), Income Tax Regs., provides that,
in determining whether an individual received over half of his
support from the taxpayer, "there shall be taken into account the
amount of support received from the taxpayer as compared to the
entire amount of support which the individual received from all
sources, including support which the individual himself
supplied." In Blanco v. Commissioner, 56 T.C. 512, 514-515
(1971), this Court held that, in establishing that more than one-
half of a dependent's support has been provided, a prerequisite
to such a showing is the demonstration by competent evidence of
the total amount of the dependent's support from all sources for
that year. If the amount of total support is not established and
cannot be reasonably inferred from competent evidence available
to the Court, it is not possible to conclude that the taxpayer
claiming the exemption provided more than one-half of the support
of the claimed dependent.
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Last modified: May 25, 2011