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the Douglas Way property and an additional insurance deduction of
$250 for the Marshall Lane property.
As to the Park Place property, respondent argues that
petitioner did not own or manage the property in 1996 and 1997.
As to the other properties, respondent contends that petitioner
did not substantiate the remaining deductions.
Discussion
1. Dependency Exemption Deductions
A taxpayer is permitted to claim as a deduction an exemption
amount for certain dependents. Sec. 151(a), (c)(1). A
taxpayer’s father and brother qualify as dependents so long as
the taxpayer provided more than half of the support to each
dependent. Sec. 152(a)(3) and (4); sec. 1.152-1(a)(1), Income
Tax Regs.
The level of support is determined by the support test, in
which the total amount of support from all sources is compared
with the amount of support actually provided by a taxpayer. The
taxpayer must initially demonstrate, by competent evidence, the
total amount of the support furnished by all sources for the
taxable years at issue. Turay v. Commissioner, T.C. Memo. 1999-
315; Keegan v. Commissioner, T.C. Memo. 1997-511; sec. 1.152-
1(a)(2)(i), Income Tax Regs. If the total amount of support is
not established, then it is generally not possible to conclude
that the taxpayer provided more than half of the support to the
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