Daniel Aaron Baker - Page 9

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          is devoid of evidence that we find to be reliable establishing              
          that A lived with her father from January until November 2003 or            
          that he otherwise had physical custody of A for a portion of 2003           
          that is greater than the portion of such year during which Ms.              
          Wus had physical custody of A.                                              
               With respect to whether petitioner provided over one-half of           
          A’s support during 2003, petitioner must show the amount of total           
          support incurred during that year on behalf of A from all                   
          sources, and he must establish that he provided over half of that           
          amount.  See Archer v. Commissioner, 73 T.C. 963, 967 (1980);               
          Blanco v. Commissioner, 56 T.C. 512, 514-515 (1971); sec. 1.152-            
          1(a)(2)(i), Income Tax Regs.                                                
               The term “support” includes food, shelter, clothing, medical           
          and dental care, education, and the like.  Sec. 1.152-1(a)(2)(i),           
          Income Tax Regs.  The total amount of support for each claimed              
          dependent provided by all sources during the year in question               
          must be shown by competent evidence.  Blanco v. Commissioner,               
          supra at 514.  Where the amount of total support incurred on                
          behalf of a child during such year is not shown, and may not                
          reasonably be inferred from competent evidence, it is not possi-            
          ble to find that the taxpayer contributed more than one-half of             
          such child’s total support.  Id. at 514-515; Fitzner v. Commis-             
          sioner, 31 T.C. 1252, 1255 (1959).                                          
               Petitioner failed to maintain any records establishing                 

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