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Moreover, deductions are a matter of legislative grace and
are allowed only as specifically provided by statute. INDOPCO,
Inc. v. Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice
Co. v. Helvering, 292 U.S. 435, 440 (1934).
A. Dependency Exemption Deductions
A taxpayer may be entitled to claim as a deduction an
exemption amount for each of his or her dependents, over half of
whose support is provided by the taxpayer. Secs. 151(c)(1),
152(a). A dependent includes a grandchild. Sec. 152(a)(1).
As to the support test, a taxpayer generally must provide
more than one-half of a claimed dependent’s support for the
calendar year in which the taxable year of the taxpayer begins.
Sec. 152(a), (c). In order to satisfy this test, a taxpayer must
establish the total support expended on behalf of the claimed
dependents from all sources for the year and demonstrate that 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).
In the present case, there is an absence of evidence
relating to the total amount of support as well as petitioner’s
share of support. While the record is replete with evidence of
petitioner being a loving and caring grandmother and her
purchases of numerous household necessities, we cannot conclude
on this record the amount of the total support for CME and CJE
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