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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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