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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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