- 3 - month. Petitioner also provided food, diapers, and clothing for Amy. Insurance paid the costs of Amy’s birth and her medical expenses. Discussion Dependency Exemption Deduction Section 151(c)3 allows a taxpayer to deduct an exemption amount for each “dependent,” as defined in section 152. Section 152(a) defines the term “dependent” to include the daughter of a taxpayer “over half of whose support, for the calendar year in which the taxable year of the taxpayer begins, was received from the taxpayer (or is treated under subsection (c) or (e) as received from the taxpayer)”. A taxpayer must establish the total cost of monetary “support” expended on behalf of a claimed dependent from all sources for the relevant year and establish that the taxpayer provided over half of the total amount.4 Blanco v. Commissioner, 56 T.C. 512, 514-515 (1971); sec. 1.152-1(a)(2)(i), Income Tax Regs. “Support” includes items such as “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 3 Unless otherwise indicated, all section references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure. 4 Petitioner does not contend that sec. 7491(a) is applicable to his case.Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011