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the total amount of the dependent’s support from all sources for
that year. If the amount of total support is not established and
cannot be reasonably inferred from competent evidence available
to the Court, it is not possible to conclude that the taxpayer
claiming the exemption provided more than one-half of the support
of the claimed dependent. Batson v. Commissioner, T.C. Memo.
2000-172.
Petitioner did not meet any of the exceptions to section
152(e)(1). Therefore, assuming that petitioner and the mother
together provided over one-half of the child’s support, the
mother is entitled to the dependency exemption for the child
pursuant to section 152(e)(1) as the custodial parent. In the
event that petitioner and the mother did not provide over one-
half of the child’s support (e.g., such support was provided by
the grandparents), it follows that petitioners are not entitled
to deduct the dependency exemption for the child pursuant to
section 152(a). Although petitioner 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 by
petitioner, the child’s mother, and the child’s grandparents.
The second issue is respondent’s disallowance of the child
tax credit claimed by petitioners under section 24. Section 24
allows a credit against the tax for any qualifying child under
the age of 17. However, a qualifying child is an individual for
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