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handwritten notations on accounting paper that the letter
characterizes as "a worksheet showing support". It purports to
compute the total monthly support contributed by petitioner for
petitioner's entire household. The latter sum is divided by 6 to
compute the "house-hold support" per person that petitioner
alleges he provided for the year. The notations indicate an
amount contributed by "Linda AFDC/Stamps (4)" and determines that
the amount contributed by petitioner is more than half the total
support of each dependent.
We see nothing in the record that would substantiate what
were essentially mere claims by petitioner that he had supplied
half the support for his niece and nephew. It seems that at the
time respondent took a position in the notice of deficiency and
the answer, petitioner had not substantiated any of the claimed
household payments.
Certainly the ownership of the family home (and an amount of
support in the form of fair rental value of the home) was in
doubt until the day before the agreed settlement. Exhibit 2 to
petitioner's letter of October 30, 1996, alleges that total
family support supplied by petitioner included $5,670 for food.
Unexplained is part V of petitioner's mother's Schedule C of her
1993 return (Exhibit 1 to petitioner's letter of October 30,
1996). The Schedule C pertains to her "child care business" in
which she "was paid by the County of Santa Clara for providing
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