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activities, respondent has pointed to likely sources of taxable
income.
At trial, petitioner neither provided documentary evidence
of the loans from Mrs. Berry or Mr. Peavy nor called them to
testify regarding those loans. Accordingly, petitioner has
failed to prove that the funds used to pay the excess of expenses
over known income are from a nontaxable source. Consequently,
respondent's position regarding petitioner's unreported income is
sustained.
Dependent Exemptions
Petitioner claimed a personal exemptions on behalf of
Jasmine and Brandy Wilson as dependents on both her 1993 and her
1994 returns. Respondent denied the exemptions. Section 151
allows a taxpayer to claim an exemption for each dependent.
Section 152 defines a dependent as:
any of the following individuals over half of whose
support, for the calendar year in which the taxable
year of the taxpayer begins, was received from the
taxpayer (or is treated under subsection (c) or (e) as
received from the taxpayer):
* * * * * * *
(9) An individual (other than an individual who
at any time during the taxable year was the spouse,
determined without regard to sec. 7703, of the
taxpayer) who, for the taxable year of the taxpayer,
has as his principal place of abode the home of the
taxpayer and is a member of the taxpayer's household.
A taxpayer claiming an exception for a dependent bears the
burden of showing that the support he provided to the dependent
constituted more than one-half of the total support of the
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