- 4 - 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 provedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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