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Petitioner's three brothers, John, Albert, and Pierce, were
adults. While none of them had full-time jobs, it appears that
each earned some income during the years at issue from odd jobs.
Petitioner's mother, Geneva, was in her 80's, and her only income
was Social Security benefits of $450 per month.
The grandniece, Char Nea Harris, was born in 1986, and both
her parents were deceased. However, at some point, the date of
which is not set out in the record, Char Nea was adopted by
petitioner's sister, Shauneille.
Petitioner's only income, except for the interest discussed
above, was her retirement benefits, which ranged from $22,990 to
$23,574 for the years at issue. Petitioner contends that she
provided more than one-half the total support for the named
dependents (except for her concession of the dependency exemption
as to her sister Shauneille).
Section 151(c) allows taxpayers to deduct an annual
exemption amount for each "dependent", as defined in section 152.
Under section 152(a), 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 brother, mother, and
foster child of the taxpayer. Sec. 152(a)(3) and (4), (9).
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