- 7 -
provided support were the child’s mother and her parents. That
also was not agreed to by the child’s mother and her parents.
One of the express conditions of section 152(e)(1) is that
the child claimed as a dependent receive over half of his support
during the calendar year from his parents, among other
requirements not pertinent here. As noted above, the child,
during the year in question, lived with the grandparents along
with his mother. There was no evidence offered to show the
amount of support the grandparents provided or the amount of
support the mother provided. Although petitioners provided
$5,502 in support, petitioners have not established that this
amount constituted more than one-half of the total support
provided to the child that year by petitioners, the child’s
mother, and the child’s grandparents.
Section 1.152-1(a)(2)(i), Income Tax Regs., provides that,
in determining whether an individual received over half of his
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, including support which the individual himself
supplied.” In Blanco v. Commissioner, 56 T.C. 512, 514-515
(1971), this Court held that, in establishing that more than one-
half of a dependent’s support has been provided, a prerequisite
to such a showing is the demonstration by competent evidence of
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011