Juanita Carter - Page 13

                                       - 13 -                                         

          documentation to establish the amounts that she provided for his            
          support.                                                                    
               On this record, petitioner failed to establish her                     
          entitlement to dependency exemptions for her brothers John,                 
          Albert, and Pierce for any of the years at issue.  Respondent,              
          therefore, is sustained on this issue.                                      
               Finally, with respect to petitioner's grandniece, Char Nea             
          Harris, who was claimed as a dependent for 1990, 1991, and 1992,            
          although the child lived with petitioner, the record also shows             
          that petitioner's sister, Shauneille, lived with petitioner and             
          Char Nea for at least 1990 and 1991.  Shauneille adopted Char Nea           
          at some time.  Shauneille was also gainfully employed during                
          these years.  Given these circumstances, it is evident to the               
          Court that Shauneille provided some support to Char Nea during              
          the years in question.  Again, petitioner presented no evidence             
          to show Char Nea's total support for these years and no                     
          documentation that would support petitioner's contention that               
          petitioner's contribution toward that support was one-half or               
          more of the total support.  Respondent, therefore, is sustained             
          on this issue.                                                              
               The third issue is whether petitioner is entitled to head-             
          of-household filing status for 1989, 1990, 1991, and 1992.                  
          Section 2(b) defines a head-of-household as an individual                   
          taxpayer who (1) is not married at the close of the taxable year,           





Page:  Previous  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  Next

Last modified: May 25, 2011