Danny M. and Alicia J. Shrader - Page 4

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          [Internal Revenue Service] shows that someone else is claiming              
          this dependent for the same tax year.”                                      
                                     Discussion                                       
               The record in this case is sparse.  There is no evidence of            
          a court decree or similar document involving Shrader and ANS’s              
          mother and covering the custody of ANS.  Petitioner testified               
          that she did not know where ANS resided during 2001 and did not             
          know how much support her mother provided to her during 2001.               
               Section 151 provides an exemption deduction for qualified              
          dependents of a taxpayer in computing taxable income.  A child of           
          a taxpayer is generally a dependent of the taxpayer only if the             
          taxpayer provides over half of the child’s support during the               
          taxable year.  Sec. 152(a).  Because petitioner cannot prove the            
          total amount of support for ANS provided during 2001, she cannot            
          establish the basic qualification for the dependency exemption.             
          See Beanco v. Commissioner, 56 T.C. 512 (1971).                             
               The reasonable inference from the stipulation that                     
          petitioners made child support payments for ANS to the State of             
          Washington Division of Child Support and that petitioners did not           
          know where ANS lived during the year in issue is that Shrader was           
          not the custodial parent of ANS.  Petitioner has not suggested              
          that any of the requirements for a noncustodial parent to claim             
          the dependency exemption have been satisfied.  See generally sec.           
          152(e); King v. Commissioner, 121 T.C. 245, 248-249 (2003); Duby            






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