Manuel R. Chavez - Page 6




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          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.                        






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