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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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