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the burden of proving that the determination is improper. Rule
142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Deductions
are a matter of legislative grace, and the taxpayer bears the
burden of proving that he is entitled to any claimed deductions.
New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934).
This includes the burden of substantiation. Hradesky v.
Commissioner, 65 T.C. 87, 89-90 (1975), affd. per curiam 540 F.2d
821 (5th Cir. 1976). Although section 7491 may shift the burden
of proof to respondent in specified circumstances, petitioner
here has not established that he meets the prerequisites under
section 7491(a)(1) and (2) for such a shift.
I. Dependency Exemptions
In general, an exemption is allowed for every dependent of a
taxpayer. Sec. 151(a), (c). A child of a taxpayer is considered
a dependent if the definitional requirements of section 151(c)(1)
are met and the taxpayer contributed over half of the support for
the child during the taxable year. Sec. 152(a)(1).
Where, as here, the parents of the child are divorced,
separated, or living apart at all times during the last 6 months
of the calendar year and where one parent has custody of the
child for more than one-half of the calendar year, the parent
with custody of the child for the greater part of the calendar
year (custodial parent) is deemed to have provided over one-half
of the support for the child for the calendar year. Sec. 152(e);
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