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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
year.
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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