John S. Turay - Page 8




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          she received wages in excess of the exemption amount in 1996.               
          See sec. 151(c).                                                            
               The record also does not provide any information as to the             
          amount of support contributed by Ms. Thompson for Briana, Randy,            
          or Damonta, although petitioner did testify that Ms. Thompson               
          worked during the years in issue.  Petitioner also testified that           
          Briana, Randy, and Damonta, along with their mother, resided with           
          him for the entire period 1995 through 1996.  Petitioner has                
          provided no documentation to show Briana, Randy, Damonta, and Ms.           
          Thompson resided with him during 1995 or 1996.  In addition, even           
          if we were to find petitioner's assertions as fact, petitioner's            
          testimony did not provide the Court with a date upon which Ms.              
          Thompson left his home with her children.  However, petitioner              
          was married to Ms. Conteh in March 1997.  Since the total amount            
          of support and the portion provided by petitioner have not been             
          made part of this record, we are unable to conclude that                    
          petitioner provided more than one-half of the total support for             
          Isatu, Mohamed, Mariatu, Briana, Randy, or Damonta.  Therefore,             
          we conclude that Isatu, Mohamed, Mariatu, Briana, Randy, and                
          Damonta do not qualify as petitioner's dependents for 1995 or               
          1996.                                                                       
               Even if we were to find petitioner meets the support                   
          requirement of section 152 for Mariatu, petitioner would not be             
          entitled to a dependency exemption deduction for her.  Mariatu              





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