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the burden of proving that he provided over one-half of a
dependent's support for any year for which the taxpayer claims an
exemption. See Seraydar v. Commissioner, 50 T.C. 756, 760
(1968). In the absence of credible evidence regarding the total
amount of support received by each claimed dependent from all
sources during the taxable year, a taxpayer cannot be said to
have carried the burden of proving that he provided more than
one-half that amount. See Blanco v. Commissioner, 56 T.C. 512,
514 (1971); Stafford v. Commissioner, 46 T.C. 515, 518 (1966).
It was respondent's position that petitioner had not shown that
he had contributed over half the support of his niece and one
nephew.
In the motion for litigation and administrative costs, it is
alleged that before the issuance of the notice of deficiency,
petitioner made an "attempt to submit the necessary
substantiation as requested by the examination letter." It is
also alleged that additional documentation was submitted and,
apparently, ignored. Petitioner fails, however, to advise either
the Court or respondent as to the nature of the substantiation
allegedly submitted.
Exhibit 2 to petitioner's representative's letter of
October 30, 1996 (attached to respondent's notice of objection to
petitioner's motion), is described in the letter as a document
submitted during the examination of the return. It is a copy of
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