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including support which the individual himself or herself
supplied. Sec. 1.152-1(a)(2)(i), Income Tax Regs. Support
includes food, shelter, clothing, medical and dental care,
education, and the like. Id.
To establish that petitioner provided more than one-half of
the claimed dependent’s support, he must first show by competent
evidence the total amount of support furnished by all sources for
the year in issue. Blanco v. Commissioner, 56 T.C. 512, 514
(1971). Petitioner has not offered competent evidence of the
total amount of support provided for his son in 2000. Aside from
his testimony, petitioner presented no evidence to corroborate or
substantiate any of the claimed support expenses, other than the
child support payments. Without proper substantiation, the Court
cannot conclude from the record that more than one-half of the
support of the claimed dependent was provided by petitioner.
Thus, petitioner has failed to establish that he provided over
half of the total support for his son. Accordingly, we hold that
petitioner is not entitled to claim his son as a dependent under
section 151. Respondent’s determination as to this issue is
sustained.
Respondent determined that petitioner’s filing status should
be changed from head of household to single. Section 2(b), in
relevant part, defines head of household as an unmarried taxpayer
who maintains as his home a household which constitutes for more
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Last modified: May 25, 2011