Loretta Manukainiu - Page 4

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            dependents in 1993.  Without proper substantiation, the Court                               
            cannot conclude from the record that more than one-half of the                              
            support of each claimed dependent was provided by petitioner.                               
            Thus, petitioner failed to prove that she provided over half of                             
            the total support of each of the claimed dependents.                                        
                  Petitioner put in evidence a worksheet on which she claims                            
            expenses in the total amount of $26,790 for the last 10 months of                           
            1993.  At trial, petitioner stated that she paid her parents                                
            between $5,000 to $7,500 in 1993 to take care of Antonio.  Thus,                            
            petitioner's position was that she had expenses somewhere between                           
            $31,790 to $34,290, at the least.  On her 1993 return, petitioner                           
            reported a total income of only $15,332.  Petitioner acknowledged                           
            that although her expenses far exceeded her income, she claimed                             
            she paid these expenses by using "a lot of credit cards".                                   
            Further, petitioner stated that she also gave her parents more                              
            than $500 in cash in 1993 for their medical bills and rented a                              
            car for her brother so he could find a job.                                                 
                  Aside from her testimony, petitioner presented no evidence                            
            to corroborate or substantiate these expenses or that these                                 
            expenses were indeed paid by petitioner.  Petitioner failed to                              
            introduce any credit card statements, a car rental bill, medical                            
            bills, mortgage statements, or even utility bills.  Further, she                            
            failed to provide any canceled checks or receipts to evidence the                           
            payments of any purported expenses.  We observe that petitioner                             

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