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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,
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