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petitioner provided more than one-half of his niece’s total
support for 2004.
For this purpose, “support” is defined as including food,
shelter, clothing, medical and dental care, education, etc. See
sec. 1.152-1(a)(2)(i), Income Tax Regs. Section 1.152-
1(a)(2)(i), Income Tax Regs., which provides:
For purposes of determining whether or not an
individual received, for a given calendar year, 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 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. Archer
v. Commissioner, 73 T.C. 963, 967 (1980); see Cotton v.
Commissioner, T.C. Memo. 2000-333; Gulvin v. Commissioner, T.C.
Memo. 1980-111, affd. 644 F.2d 2 (5th Cir. 1981); Toponce v.
Commissioner, T.C. Memo. 1968-101. Thus, 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, supra. The amount of total support
provided by the taxpayer may be reasonably inferred from
competent evidence. See Stafford v. Commissioner, 46 T.C. 515,
518 (1966).
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