Mahendra K. Tandon - Page 22

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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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