- 12 - satisfy her burden of proving that she provided over one half of Geneva's support during any of the relevant years. On this record, the Court holds that petitioner is not entitled to a dependency exemption for Geneva during any of the relevant years. The same holds for petitioner's brothers, John, Albert, and Pierce. Petitioner produced no evidence to show their total support for any of the years in which they were claimed as dependents. Petitioner made estimates of these amounts; however, not one of her estimates was corroborated by any documentary evidence. Petitioner admitted that at least two of her brothers, Albert and John, earned some amounts of money during the relevant years. Moreover, for the period from March 19, 1990, to July 3, 1991, petitioner did not provide their housing because, during that period, petitioner did not own the home her mother and the brothers occupied because that property had been acquired by the St. Louis airport authority. Additionally, John's earned income was $3,912, $4,060, $4,080, and $4,080, respectively, for 1989, 1990, 1991, and 1992. Thus, his income was greater than the "exemption amount" provided in section 151(c)(1), and that factor alone precludes petitioner's entitlement to a dependency exemption for him. See supra note 2. With respect to petitioner's brother Pierce, who was claimed as a dependent only for 1991, petitioner also provided no evidence as to his total support, nor did she present anyPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011