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that the additional tax does not apply to "Distributions made to
the employee * * * to the extent such distributions do not exceed
the amount allowable as a deduction under section 213 to the
employee for amounts paid during the taxable year for medical
care".
Section 213 allows a deduction for expenses paid during the
taxable year, not compensated by insurance or otherwise, for
medical care of the taxpayer, his spouse or a dependent (as
defined in section 152), to the extent that such expenses exceed
7.5 percent of adjusted gross income. As relevant here, section
152(a)(1) defines a "dependent" to mean a taxpayer's father or
sister who received or is treated under section 152(e) as having
received over half of his or her support from the taxpayer for
the calendar year in which the taxable year of the taxpayer
begins. To claim a dependent, taxpayers must establish the total
amount of support furnished from all sources for the taxable year
at issue and demonstrate that they provided the claimed dependent
with over half of the amount. See Archer v. Commissioner, 73
T.C. 963, 967 (1980); Blanco v. Commissioner, 56 T.C. 512,
514-515 (1971); sec. 1.152-1(a)(2)(i), Income Tax Regs.
While petitioners testified that they provided some support
to Mr. Potter and Susan, the Court cannot conclude that
petitioners provided more than one-half of the total support for
either of them. Ms. Potter testified that in 1999 Mr. Potter
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