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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
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.
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Last modified: May 25, 2011