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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. The total amount of support for each claimed
dependent furnished by all sources during the year in issue must
be established by competent evidence. Blanco v. Commissioner,
supra at 514; sec. 1.152-1(a)(1), Income Tax Regs. The amount of
support that the claimed dependent received from the taxpayer is
compared to the total amount of support the claimed dependent
received from all sources. Sec. 1.152-1(a)(2)(i), Income Tax
Regs.
Petitioner claims that Eric lived with her for the entire
year and Cassandra lived with her for 8 months during 1999.
Petitioner also claims that she provided for their every need,
including food, clothing, and shelter. She also stated that she
paid a babysitter to care for Eric all day and to provide after-
school care for Cassandra. Petitioner said she paid the
babysitter in cash and did not receive any receipts documenting
the payments. Petitioner has provided no evidence at all
regarding any amounts she may have expended to care for Eric or
Cassandra.
The Court sustains respondent’s determination that
petitioner is not entitled to dependency exemption deductions for
Eric and Cassandra in 1999.
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Last modified: May 25, 2011