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the calendar year * * * was received from the taxpayer”.
“Support” includes “food, shelter, clothing, medical and dental
care, education, and the like.” Sec. 1.152-1(a)(2)(i), Income
Tax Regs.
In determining whether an individual received more than one-
half of his or her support from the taxpayer, there shall be
taken into account the amount of support received from the
taxpayer as compared to the entire amount of support which the
individual received from all sources. Id. In other words, the
support test requires the taxpayer to establish the total support
costs for the claimed individual and that the taxpayer provided
at least half of that amount. Archer v. Commissioner, 73 T.C.
963, 967 (1980); see Cotton v. Commissioner, T.C. Memo. 2000-333;
Gulvin v. Commissioner, T.C. Memo. 1980-111, affd. 644 F.2d 2
(5th Cir. 1981); Toponce v. Commissioner, T.C. Memo. 1968-101. A
taxpayer who cannot establish the total amount of support costs
for the claimed individual generally may not claim that
individual as a dependent. Blanco v. Commissioner, 56 T.C. 512,
514-515 (1971); Cotton v. Commissioner, supra.
As previously stated, on his 2003 Federal income tax return,
petitioner claimed dependency exemption deductions for KO and NW.
Petitioner testified that he has lived with Ms. Orr and her
children, KO and NW, from taxable year 2000 through the date of
trial (February 2005). Petitioner further testified that (1) the
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