Juanita Carter - Page 11

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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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