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exemption deduction for each qualifying dependent. A sister or
nephew is considered a "dependent" so long as the taxpayer is
providing more than half the dependent's support for the taxable
year and the dependent's gross income for that year is less than
the exemption amount.3
Petitioner contends that because he sent checks to his
mother in Columbus, Georgia, to cover the first and second
mortgages on her house and other miscellaneous expenses, he is
entitled to claim his sister and nephew as dependents while they
are living in his mother's Georgia home.
Petitioner testified about his financial contributions to
his mother that she used throughout the year. The parties
stipulated that during 1992 petitioner made his mother's monthly
mortgage payments of $197.16. At trial, petitioner testified
3Sec. 152(a) defines "dependent" as:
(a) * * * any of the following individuals over
half of whose support, for the calendar year in which
the taxable year of the taxpayer begins, was received
from the taxpayer * * *
* * * * * * *
(3) A brother, sister, stepbrother, or
stepsister of the taxpayer,
* * * * * * *
(6) A son or daughter of a brother or sister
of the taxpayer,
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