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support requirement for Melissa, she must also show either that
Melissa’s gross income for 1999 was less than the exemption
amount or, because Melissa turned 20 in 1999, that Melissa was a
full-time student at an educational institution for portions of
at least 5 months during that year. See sec. 151(c)(1), (4)(A);
sec. 1.151-3(b) and (c), Income Tax Regs.
Petitioner alleges that she provided over half of Melissa’s
support during 1999. In support of that assertion, petitioner
testified that she paid a monthly rental of $550 for the
Hollywood premises so that her daughter could reside near to
where she was pursuing her fledgling recording career. We have
found that she made seven such monthly rental payments. See
supra note 4. Petitioner has failed to show that the monthly
rental expenditures represented more than half of Melissa’s total
support for 1999. Also, there is no evidence in the record that
petitioner paid for Melissa’s food, clothing, medical,
educational, or other personal expenses incurred during 1999, and
there is no evidence as to what those costs might have been.
Although it is stipulated that petitioner withdrew $24,000 from
her pension plan during 1999, there is no evidence as to what
portion, if any, of that distribution was used to make support
payments, in 1999, on Melissa’s behalf. Therefore, petitioner
has not persuaded us that she satisfies the support requirement
of section 152(a).
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