Loretta Manukainiu - Page 3

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                  Section 151 allows a taxpayer to deduct an annual exemption                           
            amount for each dependent, as defined in section 152.  Under                                
            section 152(a), the term dependent, in pertinent part, means a                              
            son, a brother, or the father or mother of the taxpayer over half                           
            of whose support was received from the taxpayer.  Sec. 152(a)(1),                           
            (3), (4).                                                                                   
                  In determining whether or not an individual received over                             
            half of his or her support from the taxpayer, there shall be                                
            taken into account the amount of support received from the                                  
            taxpayer as compared to the entire amount of support which the                              
            individual received from all sources, including support which the                           
            individual himself or herself supplied.  Sec. 1.152-1(a)(2)(i),                             
            Income Tax Regs.  Support includes food, shelter, clothing,                                 
            medical and dental care, education, and the like.  Sec. 1.152-                              
            1(a)(2)(i), Income Tax Regs.                                                                
                  After a review of the record, we find that petitioner has                             
            not established that she is entitled to the dependency exemptions                           
            claimed for Antonio, her brother, and her parents in 1993.                                  
                  To establish that petitioner provided more than one-half of                           
            the claimed dependents' support, she must first show by competent                           
            evidence the total amount of support furnished by all sources for                           
            the year in issue.  Blanco v. Commissioner, 56 T.C. 512, 514                                
            (1971).  Petitioner has not offered competent evidence of the                               
            total amount of support provided for each of the claimed                                    

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