- 5 - I. Dependency Exemption Deductions Section 151 allows a taxpayer to deduct a personal exemption, as well as dependency exemptions for the taxpayer’s dependents. See sec. 151(a), (c). Section 152(a) defines “dependent”, in pertinent part, to include “A son or daughter of a brother or sister of the taxpayer”. Sec. 152(a)(6). The claimed individuals, RJM and CGM, satisfy the definitional requirement of “dependent” within the meaning of section 152(a)(6) because they are the daughters of petitioner’s sister. To qualify as a dependent under section 152(a), the individual must have received over half of his or her support for the taxable year from the taxpayer. For this purpose, “support” is defined as including “food, shelter, clothing, medical and dental care, education, and the like.” Sec. 1.152-1(a)(2)(i), Income Tax Regs. Section 1.152-1(a)(2)(i), Income Tax Regs., further provides: For purposes of determining whether or not an individual received, for a given calendar year, over half of his support from the taxpayer, there shall be taken into account the amount of support received from the taxpayer as compared to the entire amount of support which the individual received from all sources, including support which the individual himself supplied. * * * In other words, the support test requires the taxpayer to establish the total support costs for the claimed individual and that the taxpayer provided over half of that amount. Archer v. Commissioner, 73 T.C. 963, 967 (1980); see Cotton v.Page: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007