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a member to contribute more to a common family fund
than would be spent for his support and still be
treated as not supporting himself. * * * [De La Garza
v. Commissioner, 46 T.C. 446, 449 (1966), affd. per
curiam 378 F.2d 32 (5th Cir. 1967); see also Meenk v.
Commissioner, T.C. Memo. 1970-302.]
Since the entire amount contributed by Geneva must first be
applied toward her own support, petitioner must show that the
amount of Geneva's Social Security benefits, for each year, was
less than half of the amount expended for Geneva's support in
each year, in order for petitioner to be entitled to a dependency
exemption for Geneva for each year in question.
In Blanco v. Commissioner, 56 T.C. 512, 514-515 (1971), this
Court held that, in establishing that more than one-half of a
dependent's support has been provided, a prerequisite to such a
showing is the demonstration by competent evidence of the total
amount of the dependent's support from all sources for that year.
If the amount of total support is not established and cannot be
reasonably inferred from competent evidence available to the
Court, it is not possible to conclude that the taxpayer claiming
the exemption provided more than one-half of the support of the
claimed dependent.
Petitioner failed to establish the total amount expended for
Geneva's support from all sources for the relevant years, and,
moreover, the Court is unable to reasonably infer this
information from the evidence presented. Petitioner failed to
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