Lawrence L. and Pamela J. Crane - Page 7




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          the custodial parent of record.  Sec. 152(e)(1)(B), (2)(A)(i),              
          (ii).                                                                       
               In this case, the parties agree, and the record is clear,              
          that Mr. Crane was not the custodial parent of K.M. during the              
          year in issue.  The record is also clear that Ms. Madrigal did              
          not execute a valid release pursuant to K.M. in 2002.                       
          Accordingly, our remaining inquiry is whether petitioners                   
          provided over half of the support for K.M. during the year in               
          issue.                                                                      
               Petitioners submitted evidence showing that they provided              
          $3,347.09 in support for K.M. in 2002.  Of this amount, $2,729 is           
          attributable to the aforementioned child support payments, and              
          $618.09 is attributable to medical and dental insurance costs.              
          Petitioners credibly testified that they purchased clothing and             
          food for K.M. when she was in their custody.  However, it is                
          well-settled law that the total support for each claimed                    
          dependent during the year in issue from all sources must be shown           
          by competent evidence.  See Blanco v. Commissioner, 56 T.C. 512,            
          514-515 (1971).  Here, petitioners can only substantiate                    
          $3,347.09 they provided through child support and medical costs.            
          Although we believe that petitioners did provide additional                 
          support in the form of food, clothing, and shelter during                   
          alternate weekends, 2 noncontinuous weeks of summer vacations,              
          and holidays when K.M. was in their custody, they could not                 







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