Juanita Carter - Page 6

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               Petitioner failed to satisfy her burden of proof on this               
          issue.  On this record, the Court holds that petitioner had                 
          unreported interest income of $188 for 1991 and $170 for 1992, as           
          determined by respondent in the notice of deficiency.                       
          Respondent, therefore, is sustained on this issue.                          
               The second issue is petitioner's entitlement to various                
          dependents claimed by petitioner on her income tax returns for              
          the years at issue.  The following table shows the dependents               
          claimed by petitioner, their relationship to her, and the year or           
          years such dependents were claimed:                                         

               Name & Relationship      1989      1990      1991      1992            
               Geneva Carter             U         U         U         U              
               (mother)                                                               
               John Carter               U         U         U         U              
               (brother)                                                              
               Albert Carter             U                                            
               (brother)                                                              
               Char Nea Harris                     U         U         U              
               (grandniece)                                                           
               Pierce Carter                                 U                        
               (brother)                                                              
               Shauneille Carter                  U          U                        
               (sister)                                                               
               Total                    3         4         5         3               









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