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SEC. 152(a). General Definition.--For
purposes of this subtitle, the term “dependent”
means any of the following individuals over half
of whose support, for the calendar year in which
the taxable year of the taxpayer begins, was
received from the taxpayer (or is treated under
subsection (c) or (e) as received from the
taxpayer):
* * * * * * *
(9) 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.
Consequently, an individual may qualify as a “dependent” pursuant
to section 152(a)(9) without being related to the taxpayer. Sec.
1.152-1(b), Income Tax Regs.
The record demonstrates that S.L.B.’s principal place of
abode during 2003 was petitioner’s residence and that she was a
member of petitioner’s household. Moreover, petitioner has
demonstrated that he paid the following amounts in support of
S.L.B. in 2003:
Rent and utilities1 $8,400
Clothing 1,100
Food 720
Personal hygiene 360
Transportation 600
School supplies 100
Allowance 600
1The $8,400 cost of rent and utilities is not
apportioned between petitioner and S.L.B.
We are satisfied that the aforementioned expenses represent the
total expenditures in support of S.L.B. during 2003. For the
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Last modified: May 25, 2011