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937 (1960)(finding that the taxpayer has the burden of
establishing his right to dependency exemptions and that the Court
is not authorized or required to conjecture as to the total amount
expended on the support of a taxpayer’s claimed dependent). The
record, however, reflects that Mahmoud had significant potential
sources of support other than Gabriel and Morhaf. See Terauds v.
Commissioner, T.C. Memo. 1997-64 (finding taxpayer not entitled to
dependency exemption for daughter because there was evidence
daughter was receiving support from additional sources, and
taxpayer did not establish daughter’s total support for year).
Neither petitioners nor Fuad testified that the copies of
checks drawn on Fuad’s various bank accounts that are included in
the record constituted his total contributions to the Mahmoud Daya
family during the years at issue. Petitioners provided no
evidence reflecting the total activity of Fuad’s Glendale Federal
bank account to which Mahmoud had full access during the years at
issue. Fuad testified that he opened the Glendale Federal bank
account in his name and gave Mahmoud signatory authority on the
account so that Mahmoud could use the account for “his house”. He
further testified that the account was “very inconvenient” for him
to use but that he opened the account at Glendale Federal Bank
because it was within walking distance of the Foster City
residence and convenient for Mahmoud. Petitioners offered no
explanation as to why Fuad would go to the trouble to establish a
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