Robert Cotton, Jr. - Page 9




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               The level of support is determined by the support test, in             
          which the total amount of support from all sources is compared              
          with the amount of support actually provided by a taxpayer.  The            
          taxpayer must initially demonstrate, by competent evidence, the             
          total amount of the support furnished by all sources for the                
          taxable years at issue.  See Turay v. Commissioner, T.C. Memo.              
          1999-315; Keegan v. Commissioner, T.C. Memo. 1997-511; sec.                 
          1.152-1(a)(2)(i), Income Tax Regs.  If the total amount of                  
          support is not established, then it is generally not possible to            
          conclude that the taxpayer provided more than half of the support           
          to the claimed dependents.  See Blanco v. Commissioner, 56 T.C.             
          512, 514-515 (1971); Batson v. Commissioner, T.C. Memo. 2000-172;           
          Butler v. Commissioner, T.C. Memo. 1998-355; Smith v.                       
          Commissioner, T.C. Memo. 1997-544.                                          
               From a review of this record, we cannot conclude that either           
          petitioner provided more than one-half of the support for any of            
          the claimed dependents at issue.  We are unsure as to the total             
          amount of support each dependent received from all sources.  The            
          record is also silent as to the amount of support each dependent            
          received from either of petitioners.  Therefore, respondent’s               
          determination is sustained.                                                 
          2.   Earned Income Credit                                                   
               Section 32(a) permits an “eligible individual” to claim an             
          earned income credit against the individual’s income tax                    






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