Nasser and Scottiann Zamani - Page 6

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          fully with respondent’s reasonable requests.  Petitioners                   
          therefore bear the burden of proof.                                         
               A taxpayer may be entitled to claim as a deduction an                  
          exemption amount for each of his or her dependents.  Sec. 151(c).           
          An individual must meet the following five tests in order to                
          qualify as a dependent of the taxpayer:  (1) Support test; (2)              
          relationship or household test; (3) citizenship or residency                
          test; (4) gross income test; and (5) joint return test.  Secs.              
          151 and 152; Brissett v. Commissioner, T.C. Memo. 2003-310.  If             
          the individual fails any of these tests, he or she does not                 
          qualify as a dependent.                                                     
               With respect to the support test, a taxpayer generally must            
          provide more than half of a claimed dependent’s support for the             
          calendar year in which the taxable year of the taxpayer begins.             
          Sec. 152(a).  In the case of a child of divorced parents, if the            
          child is in the custody of one or both of his parents for more              
          than half of the calendar year and receives more than half his              
          support during that year from his parents, such child shall be              
          treated, for purposes of section 152, as receiving over half of             
          his support during the calendar year from the parent having                 
          custody for a greater portion of the calendar year (the custodial           
          parent).  Sec. 152(e)(1).  The word “custody” as used in section            
          152(e) is defined in section 1.152-4(b), Income Tax Regs., which            

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