Carol Anderson - Page 6

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          credits on the ground that petitioner did not establish that the            
          amounts claimed were paid for child care expenses.                          
               Section 21(a) generally allows a credit to any individual              
          who:  (1) Maintains a household that includes as a member one or            
          more qualifying individuals, and (2) pays employment-related                
          expenses.  The allowable credit is generally based upon                     
          employment-related expenses that are paid to enable the taxpayer            
          to be gainfully employed, including expenses paid for the care of           
          a qualifying individual.  Sec. 21(b)(2).                                    
               On her 1992 and 1993 returns, petitioner claimed that she              
          paid $4,500 each year to a care provider by the name of Mary                
          Jones.  However, petitioner testified at trial that the care                
          provider's name was Ella Kennedy, and she paid her $50 per week             
          to care for her nephew, Daniel, during 1992 and her daughter,               
          Morcie, during 1993.  We are entirely unpersuaded by petitioner's           
          testimony which is not supported by any credible evidence.  The             
          alleged payments would account for only $2,600 of expenses per              
          year if made over an entire year, and neither Daniel nor Morcie             
          was under petitioner's care for an entire year.  We find that               
          petitioner has failed to prove that the amounts claimed were paid           
          for child care expenses.  We hold that petitioner is not entitled           
          to child care credits for 1992 and 1993.                                    
               The fourth issue for decision is whether petitioner is                 
          entitled to business expense deductions for 1992 in excess of the           
          amount allowed by respondent.  Petitioner claimed Schedule C                




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