James Edward Briggsdaniels - Page 4




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          for more than one-half the year was his child’s or children’s               
          principal place of abode.  Sec. 2(b)(1).                                    
               Petitioner did not submit any evidence to prove that in                
          either 1997 or 1998 he provided over half the cost of maintaining           
          as his home a household that for more than one-half the year was            
          the principal place of abode of any of his three sons.                      
          Petitioner has not shown that he qualifies for head of household            
          filing status for 1997 or 1998.  Respondent’s determination is              
          sustained.                                                                  
          Issue 2.  Dependency Exemptions                                             
               Petitioner claimed dependency exemption deductions for his             
          three sons for 1997 and 1998.  Section 151(c)(1)(B) allows a                
          dependency exemption deduction for each child of the taxpayer so            
          long as the child has not attained age 19 (24 if the child is a             
          student) at the close of the taxable year and more than half of             
          the child’s support for the taxable year was received from the              
          taxpayer.  Sec. 152(a).  In order for petitioner to establish               
          that he provided more than half of the support for any of his               
          sons, he must show by competent evidence the total support                  
          furnished for each of them from all sources during the years at             
          issue.  Blanco v. Commissioner, 56 T.C. 512, 514 (1971).                    
          Petitioner introduced no evidence of the total support furnished            
          for each of his sons from all sources for either of the years at            
          issue.  Moreover, it appears from the judgment of the Superior              






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