Jimmy A. Prince - Page 11

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               Petitioner claimed on his return that the NOL applied in               
          1998 arose in 1994 through 1997.  The record does not establish             
          that petitioner incurred an NOL in any of those years.  We                  
          sustain respondent’s determination as to this issue.                        
          5.  Dependency Exemptions/Filing Status                                     
               Section 152(a) allows a taxpayer such as petitioner to treat           
          a son and a daughter as dependents if the taxpayer provided                 
          during the taxable year more than half of the support of each.              
          See also sec. 151(a), (c) (individual taxpayer may deduct an                
          exemption amount for each of his or her dependents).  Support               
          generally includes amounts used for a dependent’s food, shelter,            
          clothing, medical and dental care, education, and the like.  Sec.           
          1.152-1(a)(2)(i), Income Tax Regs.  To meet the support test                
          required as to a dependent, a taxpayer must show:  (1) The total            
          amounts received by the dependent from all sources, (2) the                 
          amounts actually applied for the support of the dependent, (3)              
          the sources which contributed to the total support costs expended           
          on behalf of the dependent, and (4) that the taxpayer provided              
          over half of the total expenditures for the dependent’s support.            
          Barnes v. Commissioner, T.C. Memo. 1986-585.                                
               Petitioner has not persuaded us that he provided more than             
          one-half of the support of either Keauna or Zik.  We conclude               
          that he is not entitled to treat either of them as his dependent.           
          We also conclude that petitioner may not file as head of                    

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