- 11 -
contributed more than one-half. 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. Smith v. Commissioner,
T.C. Memo. 1997-544; sec. 1.152-1(a)(2)(i), Income Tax Regs. 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. Niedringhaus v. Commissioner, 99 T.C. 202, 212 (1992).
Furthermore, it is reasonable to infer that the children’s
respective mothers and fathers may have contributed a modicum
amount to their child’s total support. Without the additional
amounts petitioner may have received from the children’s extended
family, we are unable to determine the total support available to
each child by all able parties.
By failing to establish the total amount of support provided
to the children from all sources, we are unable to conclude that
petitioner provided more than one-half of the children’s total
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011