- 3 - 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 morePage: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011