Leona Payton - Page 7

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          satisfy the definition of a “dependent” within the meaning of               
          section 152(a) (the relationship or member of household                     
          requirement); and (3) petitioner must furnish more than half of             
          the dependent’s total support (the support requirement).  See               
          secs. 151(c)(1)(A); 152(a).  All requirements must be satisfied             
          for each individual claimed by petitioner.                                  
               Each claimed individual satisfies the definitional                     
          requirement of “dependent” within the meaning of section 152(a)             
          under the relationship test (as nieces, nephews, or brothers) or            
          the principal place of abode requirement (i.e., Reginald for                
          1997).  Therefore, the next issue is whether petitioner furnished           
          more than one-half of each dependent’s total support.                       
               The term “support” includes food, shelter, clothing, medical           
          and dental care, education, etc.  Sec. 1.152-1(a)(2)(i), Income             
          Tax Regs.  The amount of total support may be reasonably inferred           
          from competent evidence.  See Stafford v. Commissioner, 46 T.C.             
          515, 518 (1966).  However, where the amount of total support of a           
          dependent during the taxable year is not shown and cannot be                
          reasonably inferred from competent evidence, 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).                         
               Although we find petitioner’s testimony credible that she              
          contributed to each claimed individual’s support, the record                

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