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Section 151 provides for deductions for personal exemptions.
In this case, petitioner would be entitled to exemptions for his
mother and father if his mother and father were dependents under
section 152 and if his mother's and father's gross income were
less than the exemption amount ($2,150 for 1991). Secs. 151(c),
152; Rev. Proc. 90-64, 1990-2 C.B. 674, 675.
Petitioner's mother and father would be "dependents" if
"over half of * * * [their] support, for the calendar year in
which the taxable year of the taxpayer begins, was received from
the taxpayer". Sec. 152(a). Petitioner has not proven that he
provided over one-half of his parents' support during 1991.
Petitioner's parents lived in a home that was owned by petitioner
and at least one of his brothers. Petitioner introduced numerous
receipts in an attempt to substantiate his payment of expenses
for his parents. From the record in this case, we cannot be
certain that these expenditures were made for petitioner, his
parents, or otherwise. We are not persuaded by petitioner's or
his parents' conclusory assertions in the absence of any
corroboration.
Petitioner received at least $20,000 in gifts from his
parents during 1991. The source of these funds was not explained
at trial. Also, petitioner's mother testified that she received
an undetermined amount of interest income during 1991. During
1991, petitioner's mother also operated World Medical/Dental. No
evidence was provided as to whether or not petitioner's mother
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