Jorge Gallardo - Page 7

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          half of a dependent's support has been provided, a prerequisite             
          to such a showing is the demonstration by competent evidence of             
          the total amount of the dependent's support from all sources for            
          that year.  If the amount of total support is not established and           
          cannot be reasonably inferred from competent evidence available             
          to the Court, it is not possible to conclude that the taxpayer              
          claiming the exemption provided more than one-half of the support           
          of the claimed dependent.                                                   
               The Court is not satisfied from the evidence that petitioner           
          provided more than half of the support for his son during the               
          year at issue.  Petitioner presented no evidence to show the                
          total support that was provided to the child during 2001 and the            
          amount he provided to establish that such amount met the one-half           
          threshold required under section 152(a).  Petitioner and his                
          former wife were both employed during the year 2001, and it is              
          logical to assume, and it was not established otherwise, that,              
          until petitioner and his former wife separated on July 20, 2001,            
          the support for the son came from petitioner as well as from the            
          earnings of his former wife.  After July 20, 2001, the child no             
          longer lived with petitioner.  Petitioner admitted that he                  
          provided no support for the remainder of 2001 to his wife and               
          three children.  He only resumed support for his children in the            
          year 2002, when he was ordered to do so by the Nevada divorce               

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