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shelter, clothing, medical and dental care, education, and the
like.” Sec. 1.152-1(a)(2)(i), Income Tax Regs.
Petitioner credibly testified that he contributed money
toward his family’s expenses. Petitioner failed, however, to
establish the total amount of support that FM and MM received in
2004 or the amount of support that he provided. Accordingly,
petitioner has not demonstrated that he provided more than half
of FM’s or MM’s support. See Blanco v. Commissioner, supra at
514-515.
Petitioner contends that he and his mother agreed that
petitioner would be financially responsible for FM and MM.
Petitioner therefore believes he should be able to claim FM and
MM as dependents. Although it is not entirely clear, petitioner
may be arguing that there was a multiple support agreement with
respect to FM and MM.
Section 152(c) provides:
SEC. 152(c). Multiple Support Agreements.--For
purposes of subsection (a), over half of the support of
an individual for a calendar year shall be treated as
received from the taxpayer if—
(1) no one person contributed over half of
such support;
(2) over half of such support was received
from persons each of whom, but for the fact that
he did not contribute over half of such support,
would have been entitled to claim such individual
as a dependent for a taxable year beginning in
such calendar year;
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Last modified: May 25, 2011