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allowable to the taxpayer providing more than one-half of the
total support provided to the dependent during any given year.
Petitioner’s support did not reach that level. Most of the
support came from the other sources described. However, there
was an avenue petitioner could have availed herself of that would
have allowed her to claim the dependency exemption deduction.
She could have obtained a multiple support agreement where all
providers of support to L.H. agreed to allow the dependency
exemption deduction to one of their number. Form 2120, Multiple
Support Agreement, is the proper medium by which this is
accomplished.3
Petitioner did not include such an agreement with her
return; consequently, she is not entitled to the dependency
exemption deduction. Respondent, therefore, is sustained on this
issue.
The next issue is petitioner’s claim to head-of-household
filing status under section 2(b)(1).
3The Form 2120 is an acknowledgment by a group of
contributors who have collectively provided over one-half of a
dependent’s support for a calendar year and who may annually
designate one of their number to claim the dependency exemption
deduction for the dependent. The taxpayer who is designated as
entitled to claim the dependency exemption deduction must attach
a statement to his or her return identifying each member of the
supporting group and, in general, comply with sec. 1.152-3,
Income Tax Regs.
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Last modified: May 25, 2011