- 4 -4 calendar year in which the taxable year of the taxpayer begins, was received from the taxpayer (or is treated under subsection (c) or (e) as received from the taxpayer)”. In order to prevail, petitioner must show by competent evidence: (1) The total support provided for her son, and (2) that she provided more than half of such total support. The amount of total support may be reasonably inferred from competent evidence. Stafford v. Commissioner, 46 T.C. 515, 518 (1966). However, where the amount of total support of a child 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. 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 as to the amount she contributed to Corey’s support, the record based solely on her contributions is incomplete. Petitioner was unable to reconstruct the dollar amount of Corey’s total support for the year in issue. It appears that Mr. and Ms. White contributed a significant amount towards Corey’s support; however, we are not able to determine that amount. By failing to establish the total amount of support provided to Corey from all sources, we are unable to conclude that petitioner provided more than one-half of Corey’s total support during the year in issue. Therefore, we hold that petitioner isPage: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011