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proof has not shifted to respondent with respect to any of the
issues in the present case.
Moreover, deductions are a matter of legislative grace and
are allowed only as specifically provided by statute. INDOPCO,
Inc. v. Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice
Co. v. Helvering, 292 U.S. 435, 440 (1934).
1. Deduction for Dependency Exemption
Section 151 allows as a deduction an exemption for each
dependent of the taxpayer. See sec. 151(c). Section 152(a)
defines the term “dependent”, in pertinent part, to include “An
individual * * * who, for the taxable year of the taxpayer, has
as his principal place of abode the home of the taxpayer and is a
member of the taxpayer’s household”, provided that more than half
of the individual’s support, for 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
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