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Income Tax Regs. In determining whether an individual received
more than one-half of his or her 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. 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. 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, T.C. Memo. 2000-333.
DD was placed in petitioner and Ms. Lewis’s home as a foster
child by the Department of Social Services of South Carolina on
April 9, 2000, and DD stayed in their home until October 1, 2001.
Petitioner and Ms. Lewis received approximately $900 per month
from Social Services toward the support of DD. Petitioner and
Ms. Lewis separated in 2000, and thereafter petitioner moved out
of the house.
Petitioner admitted that after he moved out of the house
still occupied by Ms. Lewis, his new residence did not constitute
the principal place of abode for DD for taxable years 2000, 2001,
and 2002. Additionally, petitioner did not testify that he
provided over half of DD’s support for the taxable years 2000,
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