Carolyn M. Fankhanel - Page 20

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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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