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provided by all sources for the relevant year must be established
by competent evidence. Blanco v. Commissioner, supra at 514. To
determine whether a taxpayer provided more than half of the
support for a dependent, the amount of support provided by the
taxpayer is compared to the dependent’s total amount of support.
Sec. 1.152-1(a)(2)(i), Income Tax Regs. The value of support in
the form of lodging is measured by its fair rental value. Blarek
v. Commissioner, 23 T.C. 1037, 1039 (1955).
We found petitioner to be forthright and candid and his
testimony to be credible. Petitioner testified about various
amounts he expended to support Amy. Petitioner, however, did not
establish the fair rental value of the lodging supplied by Ms.
Lear, nor did petitioner establish the total amount of support
provided for Amy in 2000. We therefore sustain respondent’s
determination that petitioner is not entitled to a dependency
exemption deduction for Amy.
Earned Income Credit
Section 32(a)(1) allows an eligible individual an earned
income credit against the individual’s income tax liability. An
“eligible individual” is defined as either “any individual who
has a qualifying child for the taxable year” or any individual
who does not have a qualifying child and who meets the
requirements of section 32(c)(1)(A)(ii). Merriweather v.
Commissioner, T.C. Memo. 2002-226. A “qualifying child” is
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Last modified: May 25, 2011