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the apartment does not demonstrate that he considered the Wuol
family apartment, as opposed to his own apartment, to be his
principal place of abode in 2003. After all, petitioner paid
rent for his apartment throughout 2003 and did not have specific
living quarters in the Wuol family home. Rather, it appears that
Peter Wuol merely welcomed petitioner frequently as a guest in
his home because they were friends and from the same clan in
southern Sudan. During 2003 Peter Wuol’s home, not petitioner’s
home, was the principal place of abode for KGT and JTW who were
during that year members of Peter Wuol’s household. Thus,
petitioner did not bear a section 152(a)(9) relation to KGT or
JTW.
Support generally includes food, shelter, clothing, medical
and dental care, education, and the like. Sec. 1.152-1(a)(2)(i),
Income Tax Regs. To meet the support test of section 152(a), a
taxpayer must show: (1) The total amount received by the
dependent from all sources; (2) the amounts actually applied for
the dependent; (3) the sources which contributed to the total
support costs expended for the dependent; and (4) that the
taxpayer provided over half the expenditures for the dependent’s
support. Seraydar v. Commissioner, 50 T.C. 756, 760 (1968).
Petitioner provided only questionable receipts for $1,079 of
the amounts he contended he gave to Peter Wuol. As respondent
points out, on the basis of Peter Wuol’s 2003 tax return and
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