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then it is not possible to conclude that the taxpayer has
contributed more than one-half. See Blanco v. Commissioner, 56
T.C. 512, 515 (1971); Fitzner v. Commissioner, 31 T.C. 1252, 1255
(1959).
Total support includes, inter alia, the cost of food,
clothing, education, household utilities, or home repair expenses
necessary to maintain the household in 1997. Smith v.
Commissioner, T.C. Memo. 1997-544; sec. 1.152-1(a)(2)(i), Income
Tax Regs. According to petitioner’s testimony, Ms. Williams’s
sources of monthly income were a Social Security benefit of
approximately $300 and his monthly contribution of approximately
$200. Petitioner did not offer any other evidence, besides his
own testimony, to establish that he provided more than one-half
of Ms. Williams’s total support. Ms. Williams did not testify.
Cf. Oates v. Commissioner, T.C. Memo. 1976-347.
Without other competent evidence, we cannot determine that
petitioner provided more than one-half of his mother’s overall
support. See Blanco v. Commissioner, supra at 515. Accordingly,
we find that petitioner is not entitled to a dependency deduction
for Ms. Williams. Respondent is sustained as to the denial of a
dependency exemption for Ms. Williams.
Earned Income Credit
The relevant parts of section 32 provide that an individual
is eligible for the earned income credit if the individual has a
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