Polly M. Cherry - Page 16

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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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