Darrell D. Reed - Page 6




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          such total support.  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 an individual 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).                                                                     
               The record based solely on petitioner’s claimed                        
          contributions is incomplete.  Petitioner did not present evidence           
          to reconstruct the dollar amount of the total support for the               
          individuals claimed for the years at issue.  Total support                  
          includes, inter alia, the cost of food, clothing, education,                
          household utilities, or home repair expenses necessary to                   
          maintain the household in 1995 and 1996.  See Smith v.                      
          Commissioner, T.C. Memo. 1997-544; sec. 1.152-1(a)(2)(i), Income            
          Tax Regs.  Although petitioner claims that his records were                 
          destroyed in “a disaster in ‘98” he has not provided any details            
          of such disaster or what records were destroyed which could                 
          substantiate his expenses.  We find petitioner’s testimony vague,           
          incomplete, and self-serving.  It is well settled that we are not           
          required to accept a taxpayer’s self-serving testimony in the               
          absence of corroborating evidence.  See Niedringhaus v.                     





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