Irene E. Jones, a.k.a. Irene E. Perry-Jones a.k.a. Irene E. Perry - Page 13

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          claiming the exemption provided more than one-half of the support           
          of the claimed dependent.                                                   
               Petitioner claimed her daughter, Melanie, and her                      
          granddaughters, Nicole and Latoya, as dependents on her tax                 
          returns for the 1993 and 1994 tax years.  Petitioner has                    
          stipulated that she is not entitled to a dependency exemption for           
          her granddaughter Latoya for 1993 and 1994.  Respondent                     
          determined that petitioner did not provide more than one-half of            
          the support for Melanie and Nicole during 1993 and 1994 as                  
          required by section 152.                                                    
               Petitioner has testified that Melanie and Nicole lived with            
          her off and on during 1993 and 1994.  She has failed to provide             
          any substantiation of her testimony and also has failed to                  
          provide any means for us to decide how many weeks or months                 
          during 1993 and 1994 Melanie and Nicole actually lived with                 
          petitioner.  We have no reliable information concerning any costs           
          incurred by petitioner in connection with these visits of                   
          indeterminate length.  Even petitioner's own testimony concerning           
          the extent of the visits is approximate and uncertain.                      
               Both Melanie and Nicole received housing assistance from PHA           
          in the form of rent payments during the years in issue.  PHA paid           
          $600 per month in rent for housing occupied by Melanie and Nicole           
          during the time period petitioner claimed them as dependents.  In           
          addition, on March 24, 1993, Melanie signed a release authorizing           





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