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taxable year of the taxpayer begins, was received from the
taxpayer (or is treated under subsection (c) or (e) as received
from the taxpayer)".
To qualify for a dependency exemption deduction, a taxpayer
must establish the total support cost expended on behalf of a
claimed dependent from all sources for the year and demonstrate
that she provided over half of this 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.
The term "support" includes food, shelter, clothing, medical
and dental care, education, and the like. Sec. 1.152-1(a)(2)(i),
Income Tax Regs. The total amount of support for each claimed
dependent furnished by all sources during the year in issue must
be established by competent evidence. Blanco v. Commissioner,
supra at 514; sec. 1.152-1(a)(1), Income Tax Regs. The amount of
support that the claimed dependent received from the taxpayer is
compared to the total amount of support the claimed dependent
received from all sources. Sec. 1.152-1(a)(2)(i), Income Tax
Regs.
Petitioner testified that Contrille and Brandon lived with
her for the entire year and that she took care of the household
and paid all the bills. Petitioner did not provide any evidence
at all regarding any amounts she may have expended to care for
Contrille or Brandon.
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Last modified: May 25, 2011