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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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Last modified: May 25, 2011