Rodger L. Smith - Page 5

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          that he also contributed $155 to his mother's second mortgage and           
          sent her $100 a month4.                                                     
               We have no doubt that petitioner made significant financial            
          contributions to the household.  Petitioner, however, has not met           
          his burden of proof because he failed to substantiate the total             
          amount of support provided to Sonya and Pierre Tolbert.                     
               In order for petitioner to establish that he provided more             
          than half of his claimed dependents' support, he must first show            
          by competent evidence the total amount of support furnished by              
          all sources for the year in issue.  Blanco v. Commissioner, 56              
          T.C. 512, 514 (1971).  Petitioner has not offered evidence of the           
          total amount of support provided for Sonya and Pierre Tolbert in            
          1992.  It is therefore impossible to conclude that petitioner               
          provided more than one-half of their support for the taxable                
               There was no evidence presented on the cost of food,                   
          clothing, education, household utilities, or home repair expenses           
          which were necessary to maintain the household in 1992.  See sec.           
          1.152-1(a)(2)(i), Income Tax Regs.  Furthermore, petitioner                 
          acknowledged that additional sources of support were provided,              
          including amounts furnished by Ms. Wiggins as well as Sonya's               

               4Petitioner did not identify how many of these payments were           
          made during 1992.                                                           

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