Emmanuel M. and Blessing N. Nwankwo - Page 10

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          (TIN) has been included on the return reporting the exemption.              
          Secs. 152(a) and (b)(3), 151(e).                                            
               Section 152(a)(4) defines a dependent as including the                 
          parent of the taxpayer over half of whose support for the year              
          was received from the taxpayer.  Support generally includes                 
          amounts used for food, shelter, clothing, medical and dental                
          care, education, and the like.  Sec. 1.152-1(a)(2)(i), Income Tax           
          Regs.  To meet the support test under section 152(a), a taxpayer            
          must show:  (1) The total amounts received by the claimed                   
          dependent from all sources; (2) the amounts actually applied for            
          the support of the dependent; (3) the sources which contributed             
          to the total support costs expended on behalf of the dependent;             
          and (4) that the taxpayer provided over half of the total                   
          expenditures for the dependent’s support.  Turecamo v.                      
          Commissioner, 554 F.2d 564 (2d Cir. 1977), affg. 64 T.C. 720                
          (1975); Archer v. Commissioner, 73 T.C. 963 (1980); Seraydar v.             
          Commissioner, 50 T.C. 756, 760 (1968).                                      
               The evidence necessary to prove total support must be                  
          convincing.  Seraydar v. Commissioner, supra at 760; Stafford v.            
          Commissioner, 46 T.C. 515, 517 (1966).  If the amount of total              
          support is not shown and cannot be reasonably inferred from the             
          competent evidence available, then it is impossible to conclude             
          that the taxpayer furnished more than half.  Blanco v.                      







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