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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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