Astrida Terauds - Page 4

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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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