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discussed infra, petitioner failed to establish her entitlement
to head-of-household filing status under section 1.2-2(d), Income
Tax Regs.
Section 151(c) allows dependency exemption deductions for
each dependent as defined in section 152(a). Section 152(a)
defines a dependent as an individual over half of whose support
was received from the taxpayer. Eligible individuals who may be
claimed as dependents include a son or daughter of the taxpayer.
In determining whether an individual received over half of his
support from the taxpayer, “there shall be taken into account the
amount of support which the individual received from all sources,
including support which the individual himself supplied.” Sec.
1.152-1(a)(2)(i), Income Tax Regs. Petitioner must demonstrate
through competent evidence the total amount of support from all
sources available during the year in issue. Blanco v.
Commissioner, 56 T.C. 512, 514-515 (1971). If petitioner fails
to provide this information, this Court cannot conclude that the
taxpayer claiming the exemption provided more than one-half of
the support of the claimed dependent.
Petitioner testified that Yia Her, the father of her six
children, moved out of her residence in December 2000; that the
three children she claimed as dependents lived with her during
2001; and that the other three children lived with their father,
Mr. Her. Petitioner also testified that she had never been
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