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(2) more than half of the individual’s support must be received
from the taxpayer, and (3) the individual must have as his or her
principal place of abode the home of the taxpayer and be a member
of the taxpayer’s household. Secs. 151(c)(1)(A), 152(a), (a)(9).
The Court concludes that petitioner has not shown that he
provided more than half of TE and TG’s support for the calendar
year.
“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.
Commissioner, T.C. Memo. 2000-333. Thus, a taxpayer who cannot
establish the total amount of support costs for the claimed
individual generally may not claim that individual as a
dependent. Blanco v. Commissioner, 56 T.C. 512, 514-515 (1971);
Cotton v. Commissioner, supra.
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