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with the requirements of section 7491(a)(2)(A) and (B) to
substantiate items, maintain required records, and fully
cooperate with respondent’s reasonable requests. Accordingly,
the burden does not shift.
1. Dependency Exemption Deductions
A taxpayer may be entitled to claim as a deduction an
exemption amount for each of his or her dependents, over half of
whose support is provided by the taxpayer. Secs. 151(c)(1),
152(a). A dependent includes a son or daughter of a sister of
the taxpayer. Sec. 152(a)(6).
As to the support test, a taxpayer generally must provide
more than half of a claimed dependent’s support for the calendar
year in which the taxable year of the taxpayer begins. Sec.
152(a). In order to satisfy this test, a taxpayer must establish
the total support expended on behalf of the claimed dependents
from all sources for the year and demonstrate that he provided
more than half of this amount. See Archer v. Commissioner, 73
T.C. 963, 967 (1980); Blanco v. Commissioner, 56 T.C. 512, 514-
515 (1971).
There is an absence of evidence relating to the total amount
of support as well as petitioner’s share of support. While there
is some general information as to purchase of groceries, payment
of rent, and payments of other household expenses by petitioner,
we cannot conclude from this meager record the amount of the
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Last modified: May 25, 2011