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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 daughter of the
taxpayer. See sec. 152(a)(1).
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.
Petitioner was incarcerated for the first 6 months of the
year 2000 and admitted he provided no support to La Toya Johnson
during that period. After petitioner was released from
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Last modified: May 25, 2011