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each issue. The determinations of the Commissioner in the notice
of deficiency are presumed correct, and the burden is on the
taxpayer to show that they are in error. Rule 142(a); Welch v.
Helvering, 290 U.S. 111, 115 (1933). Additionally, deductions
are a matter of legislative grace, and the taxpayer must satisfy
the specific statutory requirements for any deduction claimed.
INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992).
1. Claimed Dependency Exemption Deduction
The first issue is petitioner's claim to a dependency
exemption deduction for her daughter Sandra for 1987. Petitioner
claimed Sandra as a dependent on her 1986 and 1987 returns;
however, respondent disallowed the exemption for 1987. The
reason stated for the disallowance is that petitioner did not
establish that she had provided more than one-half of Sandra's
support during 1987.
Section 151(c)(1) generally allows as a deduction an
exemption for each dependent of a taxpayer as defined in section
152. Section 152(a) provides, in general, that the term
"dependent" means certain individuals over half of whose support
was received from the taxpayer during the taxable year in which
such individuals are claimed as dependents. Eligible individuals
who may be claimed as dependents include, among others, a son or
daughter of the taxpayer. Sec. 152(a)(1). Section 151(c)(1)
further provides that, if the claimed dependent is a child of the
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