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taxable year of the taxpayer begins, was received from the
taxpayer”. In determining whether petitioner supplied over half
of the support, Social Security benefits received by the brother
or mother are considered. See Carter v. Commissioner, T.C. Memo.
1998-243, affd. per curiam without published opinion 187 F.3d 640
(8th Cir. 1999).
When petitioner was asked how much support he provided, his
answer was “Over half their income. * * * It was over * * *
$7,000" for each. Putting aside the fact that we simply do not
believe that petitioner spent $14,000 on his brother and mother,3
there is nothing in the record to indicate what the total support
was for either. Accordingly, petitioner has not established that
either his brother or his mother received more than half of their
support from petitioner. Respondent’s determination with respect
to the dependency exemption issue is sustained.
Petitioner calculated his 1996 and 1997 Federal income tax
liabilities using the head of household filing status based on
3 For example, for 1996 petitioner reported income of $29,594
and a loss of $15,065 from Schedule C, Profit or Loss From
Business, for a total income of $14,529. He had approximately
$2,500 withheld for Social Security and medicare taxes, $1,138
withheld for State income taxes, and $3,326 withheld for Federal
income taxes. If he had paid $14,000 for the support of his
brother and mother, the total amounts withheld and paid to them
($20,964) would have exceeded his total income. When this was
pointed out, petitioner then claimed that he also received
approximately $30,000 in disability benefits from the Department
of Veterans Affairs. There is nothing in the record, except
petitioner’s naked testimony, to support this claim.
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