- 20 - 142(a). Petitioner has failed to prove that she provided over half of Zachary’s support for any of the years in question. Petitioner has made no persuasive showing of the amounts expended by her in support of Zachary for any of the years in issue. She has made no showing of the total amounts expended for Zachary’s support during those years. We have found that petitioner’s father paid $4,000 and $13,000 towards Zachary’s college costs in 1988 and 1989, respectively, and that Zachary earned $8,234 in 1990. Absent some estimate of the total dollar amount expended for Zachary's support, we cannot accurately determine whether petitioner provided more than one-half of the total amount spent in support of Zachary. See Pillis v. Commissioner, 47 T.C. 707, 708-709 (1967), affd. per curiam 390 F.2d 659 (4th Cir. 1968). Petitioner's minimal showing of the support she provided to Zachary during her taxable years 1988 through 1990 is insufficient to overcome the presumptive correctness of respondent's determination that petitioner did not furnish over one-half of Zachary's support during these years. Respondent's determination of deficiencies is sustained to the extent of the adjustments disallowing additional exemptions for Zachary for 1988 through 1990. IV. Interest Income Respondent made adjustments increasing petitioner’s income by $3,043, $7,085, and $2,683 for 1991, 1992, and 1993,Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011