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over one-half of Anupam's support in 1986; petitioner asserts
that he did provide over one-half of Anupam's support.
In 1986, section 151(c)(1) allowed a dependency exemption
for each dependent whose gross income for the calendar year was
less than the exemption amount or who was a qualifying child of
the taxpayer. Section 152(a) defines "dependents" as certain
individuals over one-half of whose support was received from the
taxpayer during the calendar year.
In order for petitioner to establish that he provided more
than one-half of his claimed dependent's support, he 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 evidence of the
total amount of support provided Anupam in 1986. Without proper
substantiation, the Court cannot conclude from the record that
more than one-half of Anupam's support was provided by
petitioner. It is therefore impossible to conclude that
petitioner provided more than one-half of Anupam's support for
1986. Accordingly, we sustain respondent's determination.8
Self-Employment Tax
Respondent argues that petitioner had additional self-
employment income in 1986 and 1987 based on petitioner's
8 We note that petitioner testified, and argued, that
Anupam was both petitioner's brother and his cousin.
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