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C. Dependency Exemption Deductions
On each of his returns for 1998 and 1999, petitioner claimed
dependency exemption deductions for both of his parents. In the
notice of deficiency, respondent denied the deductions.
A taxpayer is entitled to a deduction for an exemption for
each individual who qualifies as the taxpayer’s dependent under
sections 151 and 152. Secs. 151(a), (c), 152. The term
“dependent” includes a taxpayer’s parents over half of whose
total support is received from the taxpayer for the calendar
year. Sec. 152(a)(4). “The term ‘support’ includes food,
shelter, clothing, medical and dental care, education, and the
like.” Sec. 1.152-1(a)(2)(i), Income Tax Regs.
Petitioner contends that he contributed over half of his
parents’ total support. In support of this contention,
petitioner introduced at trial a worksheet indicating that his
parents’ sole source of income was Lorant’s annual Social
Security benefits of approximately $9,036, that his parents’
total support cost was $34,625, and that petitioner contributed
$25,588 towards his parents’ support.9 We do not find the
worksheet to be reliable because petitioner did not have personal
knowledge of the information in the worksheet, which was
completed by Lorant, and petitioner did not present any testimony
9 We note that the worksheet erroneously counted rent for
the Victorville home as an expense of the entire household and as
another separate expense of the dependents.
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