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he is entitled to the deductions claimed. Rule 142(a)(1);
INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); New
Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934). In
addition, a taxpayer must keep sufficient records to substantiate
any deductions claimed. Sec. 6001; New Colonial Ice. Co. v.
Helvering, supra at 440. Section 7491(a) does not apply in this
case because petitioner did not introduce credible evidence that
he is entitled to the deduction he seeks.
In general, under section 151(a) and (c), a taxpayer is
allowed a dependency exemption deduction for each dependent.
Sec. 152(a)(1). The definition of a “dependent” provided by
section 152(a) includes a child of the taxpayer over half of
whose support for the year was provided by the taxpayer. See
sec. 1.152-1(a), Income Tax Regs. In the case of a child of
divorced parents, the child generally is treated as receiving
over half his support from the parent having custody for the
greater portion of the year. Sec. 152(e)(1) and (2).
In order to satisfy the support test of section 152(a) so as
to be entitled to a dependency exemption deduction, the taxpayer
must prove the amount of total support the child received during
the year and establish that the support that the taxpayer
provided exceeds half the total. Rule 142(a); Stafford v.
Commissioner, 46 T.C. 515, 517-518 (1966); Vance v. Commissioner,
36 T.C. 547, 549 (1961); Lear v. Commissioner, T.C. Memo. 2004-
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Last modified: November 10, 2007