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support may reasonably be inferred from competent evidence.
Blanco v. Commissioner, supra at 514-515. However, if the amount
of total support is not established, and cannot reasonably be
inferred from competent evidence, then it is not possible to
conclude that the taxpayer contributed more than one-half. Id.;
Jeter v. Commissioner, supra.
There is little doubt that petitioner provided for the
support of Mrs. Morgan during the year in issue. The extent of
the support, however, is far from clear. Petitioner estimated
that he spent $850 per month supporting Mrs. Morgan. He
testified that he paid for her general living expenses, including
her utilities, food, and clothing. However, petitioner provided
supporting documentation for only minimal expenditures for the
support of his mother during 1997. Petitioner argues that his
reported wages of $44,799 for 1997 show that he had enough income
to provide for more than half of Mrs. Morgan’s support during
1997. While this may be true, there is insufficient evidence to
establish how much of petitioner’s income actually was spent on
supporting his mother. Petitioner had business and personal
obligations, and he had a brother who may have contributed to
Mrs. Morgan’s support even though petitioner claims that the
brother had significant other family obligations.
Petitioner offered insufficient evidence to establish either
the total amount of Mrs. Morgan’s support or his own
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