Astrida Terauds - Page 5

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          taxpayer claiming the exemption, the child must not have attained           
          the age of 19 at the close of the calendar year or must be a                
          student.  Sec. 151(c)(1)(B).                                                
               During 1987, Sandra had not attained the age of 19 at the              
          close of the year.  However, she had a part-time job at a                   
          supermarket during 1987.  Based on petitioner's testimony at                
          trial, Sandra's gross income from this job was "over $1,900"                
          during 1987.                                                                
               Petitioner presented no evidence to establish the total                
          support provided to Sandra during 1987, and that, of the total              
          support provided, more than one-half of such amount was provided            
          by petitioner.  See Blanco v. Commissioner, 56 T.C. 512, 514                
          (1971).  Although petitioner provided Sandra with a place of                
          abode, food, and perhaps some clothing, the record shows, based             
          on petitioner's testimony, that Sandra had other means of support           
          during 1987 in addition to the earnings from her part-time job              
          and petitioner's support.  Sandra's father provided her $100 per            
          week during 1987.  On this record, petitioner has not established           
          that she provided more than half of Sandra's total support during           
          1987.  Respondent, therefore, is sustained on this issue.4                  

               Petitioner offered no testimony as to her relationship with            
          Sandra's father, and, in particular, whether she and Sandra's               
          father were married to each other; whether they were divorced or            
          legally separated and, if so, the date thereof, and who was the             
          custodial parent; and whether there were any agreements or court            
          decrees regarding which parent was entitled to the dependency               

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