Joseph Lee Marshall - Page 8




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          must maintain the household, and both the taxpayer and the                  
          individual must occupy the household for the taxable year.  Sec.            
          1.152-1(b), Income Tax Regs.  A taxpayer maintains a household              
          when he pays more than half of the expenses for the household.              
          Rev. Rul. 64-41, 1964-1 C.B. 84.  FA and AA had the same                    
          principal place of abode as petitioner, who was unmarried.                  
          Further, petitioner, FA, and AA occupied the household for 2005.            
               The record does not provide us with sufficient evidence of             
          the total available sources of support for the children or that             
          petitioner paid more than half of the expenses for the household.           
          Thus, FA and AA are not considered related to petitioner for                
          purposes of section 152(d)(1)(A).                                           
               Even if we concluded that FA and AA were related to                    
          petitioner within the meaning of section 152(d)(2)(H), section              
          152(d)(1)(C) requires that petitioner also provide over half of             
          the total support for the children for the taxable year.  In                
          order to meet this burden of support, petitioner must establish,            
          by competent evidence, the total amount of support furnished for            
          the taxable year at issue.  See Blanco v. Commissioner, 56 T.C.             
          512, 514-515 (1971); Cotton v. Commissioner, T.C. Memo. 2000-333.           
          Support includes “food, shelter, clothing, medical and dental               
          care, education, and the like.”  Sec. 1.152-1(a)(2)(i), Income              
          Tax Regs.                                                                   








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