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items, maintain records, and cooperate fully with respondent’s
reasonable requests. Petitioner therefore bears the burden of
proof.
I. Deductions for Dependency Exemptions
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. If the individual fails any of these tests, he or
she does not qualify as a dependent.
For a claimed dependent to satisfy the support test a
taxpayer generally must provide more than half of the claimed
dependent’s support for the calendar year in which the taxable
year of the taxpayer begins. Sec. 152(a). The taxpayer must
initially demonstrate, by competent evidence, the total amount of
the support furnished by all sources for the taxable year at
issue. Blanco v. Commissioner, 56 T.C. 512, 514 (1971); Cotton
v. Commissioner, T.C. Memo. 2000-333. If the total amount of
support is not established, then it is generally not possible to
conclude that the taxpayer provided more than half of the support
to the claimed dependent. Blanco v. Commissioner, supra at 514-
515; Cotton v. Commissioner, supra. Support includes “food,
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Last modified: May 25, 2011