David B. and Sharon J. D'Amours - Page 14

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          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 at least half of that amount.  Archer v. Commissioner,             
          73 T.C. 963, 967 (1980); see Cotton v. Commissioner, T.C. Memo.             
          2000-333; Gulvin v. Commissioner, T.C. Memo. 1980-111, affd. 644            
          F.2d 2 (5th Cir. 1981); Toponce v. Commissioner, T.C. Memo.                 
          1968-101.  A taxpayer who cannot establish the total amount of              
          support costs for the claimed individual generally may not claim            
          that individual as a dependent.  Blanco v. Commissioner, 56 T.C.            
          512, 514-515 (1971); Cotton v. Commissioner, supra.                         
               Petitioner testified that David B. D’Amours, Jr., resided              
          with Ms. Pond during taxable year 2002.  Petitioner further                 
          testified that he provided some support for David B. D’Amours,              
          Jr.  However, petitioner did not testify as to any specific                 
          amounts of support given to David B. D’Amours, Jr., or to the               
          total annual cost of support for David B. D’Amours, Jr.                     
          Petitioner has not carried his burden of proof in showing either            
          the total support for David B. D’Amours, Jr., for taxable year              
          2002 or that he provided over one-half of that support as                   
          required under section 152(a).  Therefore, petitioner is not                







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