Carol Anderson - Page 4

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          Commissioner, 338 F.2d 602, 605 (9th Cir. 1964), affg. 41 T.C.              
          593 (1964); Niedringhaus v. Commissioner, 99 T.C. 202, 219-220              
          (1992); Tokarski v. Commissioner, 87 T.C. 74, 77 (1986); Hradesky           
          v. Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam 540 F.2d           
          821 (5th Cir. 1976).  Taxpayers are required to substantiate                
          amounts claimed as deductions, credits, etc., by maintaining the            
          records needed to establish such entitlement.  Sec. 6001; sec.              
          1.6001-1(a), Income Tax Regs.                                               
               An individual taxpayer is allowed as a deduction in                    
          computing taxable income an additional exemption for each                   
          dependent as defined in section 152.  Sec. 151(c)(1).  A                    
          dependent is generally defined as an individual who receives over           
          half of his support from the taxpayer in the calendar year in               
          which the taxpayer's taxable year begins.  Sec. 152(a).                     
          Individuals listed under this general definition include, among             
          others, an individual who is a son or daughter of a brother or              
          sister of the taxpayer.  Sec. 152(a)(6).                                    
               Respondent argues that petitioner failed to meet the support           
          requirements of section 152(a).  We agree.  Petitioner presented            
          no records to establish that she provided more than half of her             
          nieces' and nephews' support during 1992.  She has not convinced            
          us that the children were not supported by public assistance                
          payments received by their mother or amounts received from their            
          father (petitioner's brother).  In the absence of any                       
          corroborating evidence, we find that petitioner has not proved              




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