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proof has not shifted to respondent with respect to the issue in
the present case.
Moreover, deductions are a matter of legislative grace and
are allowed only as specifically provided by statute. INDOPCO,
Inc. v. Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice
Co. v. Helvering, 292 U.S. 435, 440 (1934).
Section 151(a) authorizes deductions for the exemptions
provided by that section. In particular, section 151(c)(1)
provides an exemption for each of a taxpayer’s dependents, as
defined in section 152, who is a child of the taxpayer and who
has not reached the age of 19 by the close of the taxable year.
Sec. 151(c)(1)(B).
Section 152(a)(1) defines the term “dependent” to include a
taxpayer’s child, provided that more than half of the child’s
support was received from the taxpayer or is treated under
section 152(e) as received from the taxpayer.
In the case of a child of divorced parents, section
152(e)(1) provides as a general rule that the child shall be
treated as receiving over half of his or her support from the
custodial parent. Section 1.152-4(b), Income Tax Regs., provides
that custody “will be determined by the terms of the most recent
decree of divorce” if there is one in effect. In the event of
so-called split or joint custody, “‘custody’ will be deemed to be
with the parent who, as between both parents, has the physical
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