Audrey A. Carlisle - Page 5

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          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 is            

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