- 5 - 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;Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011