Rodger L. Smith - Page 3

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               Both Sonya and Pierre Tolbert received some form of public             
          assistance while living in Ms. Wiggins' home.  Sonya Tolbert                
          received $110 each month in food stamps and Pierre Tolbert's                
          medical expenses were paid by the State of Georgia Department of            
          Medical Assistance.                                                         
               Petitioner filed as head of household for the taxable year             
          1992 and claimed dependency exemptions for both Sonya and Pierre            
          Tolbert.  Petitioner also claimed the earned income credit in               
          1992 for Sonya and Pierre Tolbert in the amount of $1,261.                  
               Respondent disallowed petitioner's claim for dependency                
          exemptions on the grounds that he did not provide over one half             
          of Sonya's and Pierre's support during 1992.  Respondent also               
          denied petitioner's claim for the earned income credit and his              
          head of household filing status.                                            
               Respondent's determinations are presumed correct, and                  
          petitioner has the burden of proving them erroneous.  Rule                  
          142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933).  Taxpayers            
          must maintain adequate records to substantiate the amount of any            
          deductions or credits claimed.  Sec. 6001; sec. 1.6001-1(a),                
          Income Tax Regs.                                                            
               The first issue we address is whether petitioner is entitled           
          to claim dependency exemption deductions for Sonya and Pierre               
          Tolbert.  Section 151(c)(1) allows a taxpayer to claim an                   

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