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burden of proof should shift to respondent. Petitioner,
therefore, bears the burden of proving that respondent’s
determinations in the notice of deficiency are erroneous. See
Rule 142(a); Welch v. Helvering, supra at 115.
Dependency Exemption Deductions
Petitioner claimed dependency exemption deductions for
A.O.N. and A.V.N. for taxable year 2003. Section 151 allows
deductions for personal exemptions, including exemptions for
dependents of the taxpayers. See sec. 151(c). Section 152(a)
defines the term “dependent”, in pertinent part, to include a son
or daughter of the taxpayer over half of whose support for the
calendar year was received from the taxpayer. The term “support”
includes food, shelter, clothing, medical and dental care,
education, and the like. Sec. 1.152-1(a)(2)(i), Income Tax Regs.
In determining whether an individual received more than half of
his or her support from a 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. Id.
Section 152(e) provides a special support test for children
of individuals who are no longer or were never married. See King
v. Commissioner, 121 T.C. 245, 248-249 (2003). Simply put,
section 152(e) provides that if a child receives over half of his
or her support from his or her parents and is in the custody of
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