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satisfy her burden of proving that she provided over one half of
Geneva's support during any of the relevant years. On this
record, the Court holds that petitioner is not entitled to a
dependency exemption for Geneva during any of the relevant years.
The same holds for petitioner's brothers, John, Albert, and
Pierce. Petitioner produced no evidence to show their total
support for any of the years in which they were claimed as
dependents. Petitioner made estimates of these amounts; however,
not one of her estimates was corroborated by any documentary
evidence. Petitioner admitted that at least two of her brothers,
Albert and John, earned some amounts of money during the relevant
years. Moreover, for the period from March 19, 1990, to July 3,
1991, petitioner did not provide their housing because, during
that period, petitioner did not own the home her mother and the
brothers occupied because that property had been acquired by the
St. Louis airport authority. Additionally, John's earned income
was $3,912, $4,060, $4,080, and $4,080, respectively, for 1989,
1990, 1991, and 1992. Thus, his income was greater than the
"exemption amount" provided in section 151(c)(1), and that factor
alone precludes petitioner's entitlement to a dependency
exemption for him. See supra note 2.
With respect to petitioner's brother Pierce, who was claimed
as a dependent only for 1991, petitioner also provided no
evidence as to his total support, nor did she present any
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