Jorge Gallardo - Page 6

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               With respect to the first issue, whether petitioner is                 
          entitled to a dependency exemption deduction, section 151(c)                
          allows taxpayers to deduct an annual exemption amount for each              
          dependent as defined in section 152.  Under section 152(a), the             
          term "dependent" means certain individuals over half of whose               
          support was received from the taxpayer during the taxable year in           
          which such individuals are claimed as dependents.  Eligible                 
          individuals who may be claimed as dependents include, among                 
          others, a son or stepson of the taxpayer.  Sec. 152(a)(1) and               
          (2).  Section 152(e)(1)(A)(iii) further provides an additional              
          requirement pertinent to the facts of this case that, when the              
          parents are not divorced or legally separated under a decree of             
          divorce or separate maintenance, in order for the custodial                 
          parent to be entitled to the dependency exemption deduction, the            
          parents must have lived apart during the last 6 months of the               
          taxable year.                                                               
               Section 1.152-1(a)(2)(i), Income Tax Regs., provides that,             
          in determining whether an individual received over half of his              
          support from the taxpayer, "there shall be taken into account the           
          amount of support received from the taxpayer as compared to the             
          entire amount of support which the individual received from all             
          sources, including support which the individual himself                     
          supplied."  In Blanco v. Commissioner, 56 T.C. 512, 514-515                 
          (1971), this Court held that, in establishing that more than one-           

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