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credits on the ground that petitioner did not establish that the
amounts claimed were paid for child care expenses.
Section 21(a) generally allows a credit to any individual
who: (1) Maintains a household that includes as a member one or
more qualifying individuals, and (2) pays employment-related
expenses. The allowable credit is generally based upon
employment-related expenses that are paid to enable the taxpayer
to be gainfully employed, including expenses paid for the care of
a qualifying individual. Sec. 21(b)(2).
On her 1992 and 1993 returns, petitioner claimed that she
paid $4,500 each year to a care provider by the name of Mary
Jones. However, petitioner testified at trial that the care
provider's name was Ella Kennedy, and she paid her $50 per week
to care for her nephew, Daniel, during 1992 and her daughter,
Morcie, during 1993. We are entirely unpersuaded by petitioner's
testimony which is not supported by any credible evidence. The
alleged payments would account for only $2,600 of expenses per
year if made over an entire year, and neither Daniel nor Morcie
was under petitioner's care for an entire year. We find that
petitioner has failed to prove that the amounts claimed were paid
for child care expenses. We hold that petitioner is not entitled
to child care credits for 1992 and 1993.
The fourth issue for decision is whether petitioner is
entitled to business expense deductions for 1992 in excess of the
amount allowed by respondent. Petitioner claimed Schedule C
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