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claimed dependent from all sources for the year and demonstrate
that he or she provided more than half of this amount. See
Archer v. Commissioner, 73 T.C. 963, 967 (1980); Blanco v.
Commissioner, 56 T.C. 512, 514-515 (1971); sec. 1.152-1(a)(2)(i),
Income Tax Regs.
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 did not provide any evidence of total support for
the children and his aunt. He provided no evidence other than
his testimony regarding any amounts he may have expended to care
for ZJ, JO, AR, or Ms. Onorati. The Court sustains respondent’s
determination that petitioner is not entitled to dependency
exemption deductions for ZJ, JO, AR, or Ms. Onorati in 2002.
2. Head of Household Filing Status
Section 1(b) imposes a special tax rate on individuals
filing as head of household. As relevant herein, section 2(b)
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