Andre L. Wilson - Page 7

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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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