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Section 152(a) provides that for a taxpayer to take a dependency exemption, the potential dependent must satisfy either the qualifying child requirement or the qualifying relative requirement. Section 152(b)(2) indicates that the taxationis not permitted a dependency exemption for a married dependent if the married individual files a joint return. Pursuant to section 152(c), the term “qualifying child” refers to an individual who has not furnished over one-half of his or her own support and who has not attained the age of 19 or who has not attained the age of 24, if a full-time student, as of the close of such calendar year. The term “qualifying relative” under section 152(d) includes, but is not limited to, an individual whose gross income is less than the exemption amount and to whom the taxpayer provides over-half of the total individual’s support for the calendar year in which such taxable year begins. Under Reg. Sec. 1.152 (a), support received from the taxpayer is compared to the entire amount of support which the potential dependent received from all sources, including support which the individual supplied himself. Support includes food, shelter, medical and dental care, education, recreation, transportation, and similar necessities. For the purposes of computing the amount which is contributed for the support, non-taxable income which is ordinarily excludable from gross income must be included.
Pursuant to the IRS Publication 501, medical insurance expenses are to be included in total support cost. However, life insurance premiums need to be excluded. Expenses that are not directly related to any one member of a household, such as the cost of food and lodging for the household, must be divided among the members of the household. A person's own funds are not support unless they are actually spent for support.
Rev. Rul. 77-282, 1977-2 provides that the FMV of an automobile that is purchased and owned by the potential dependent is to be included in the individual’s support for the year of purchase.
Pursuant to the IRS Publication 501, a full-time student is a student who is enrolled for the number of hours or courses the school considers to be full-time attendance. Student loan obtained by the individual to be claimed as dependent should be included in calculation of the individual’s own support [Philip J. McCauley, 56 T.C. 48 (1971)].
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