- 4 - that she provided more than half of this 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 furnished by all sources during the year in issue must be established by competent evidence. Blanco v. Commissioner, supra at 514; sec. 1.152-1(a)(1), Income Tax Regs. The amount of support that the claimed dependent received from the taxpayer is compared to the total amount of support the claimed dependent received from all sources. Sec. 1.152-1(a)(2)(i), Income Tax Regs. Petitioner testified that “I feel that I should claim my brother as a dependent.” When asked by the Court for her proof of support, petitioner replied: “Well, I don’t have that proof.” Petitioner has already admitted that she has no proof of support for BD. The Court sustains respondent's determination that petitioner is not entitled to dependency exemption deductions for 2003. Head of Household Petitioner filed as a “head of household” for 2003. In the notice of deficiency, respondent determined petitioner’s properPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011