Thomas Samuel Lear - Page 3

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          month.  Petitioner also provided food, diapers, and clothing for            
          Amy.  Insurance paid the costs of Amy’s birth and her medical               
          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.                                                     

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