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1992, petitioner also had a second, part-time job promoting
credit cards at shopping malls and college campuses.
Petitioner and her husband, Morris Richard Anderson (Mr.
Anderson), were married on October 18, 1990. Marital
difficulties arose, and Mr. Anderson vacated the marital
residence in 1991 and never returned. They are not legally
separated or divorced. Petitioner has a daughter, Morcie
Anderson, who was born in October 1993.
Petitioner's sister-in-law was a drug addict who was in and
out of drug rehabilitation programs during 1992. From March 1992
until December 1992, petitioner's two nieces, Shannon Givens and
Timpest Givens, and two nephews, Benjamin Givens and Daniel
Wilcher, stayed at petitioner's home.
The first issue for decision is whether petitioner is
entitled to dependency exemption deductions for her two nieces
and two nephews for 1992. Petitioner claimed dependency
exemption deductions for Shannon, Timpest, Benjamin, and Daniel
on her 1992 return. Respondent disallowed the claimed deductions
in the statutory notice of deficiency.
Respondent's determinations in the statutory notice of
deficiency are presumed to be correct, and petitioner bears the
burden of proving otherwise. Rule 142(a); Welch v. Helvering,
290 U.S. 111, 115 (1933). In deciding whether this burden is
satisfied, the Court is not bound to accept petitioner's self-
serving, unverified, and undocumented testimony. Wood v.
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