Jorge Maliabo Balumba - Page 6

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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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