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the exemption provided more than one-half of the support for the
claimed dependent. Id. at 514-515.
Petitioner failed to establish that he provided more than
one-half of the total support of his sons that lived with him.
See Rule 142(a).2 On his 1999 Federal income tax return
petitioner reported total income of $17,415. In contrast his
parents reported total income exceeding $100,000 for the same
year. Petitioner and his two sons lived in petitioner’s parents’
home for the entire year 1999. Petitioner has failed to
establish either the total amount of support that petitioner’s
sons received from all sources or the amount of support that they
received from petitioner. Other than alleged receipts for his
monthly rent payments of $300 to his parents, the only evidence
of support that petitioner presented to the Court was his
unsubstantiated testimony that he provided “100 percent” of the
support of his sons. He presented no checks to substantiate his
alleged payments. He had no grocery receipts or receipts for
alleged payments for clothing, and he admitted that he made no
payments for his sons’ entertainment. The receipts that
petitioner introduced concerning supposed payments of rent to his
mother all appear to have been prepared and signed at the same
time. Petitioner’s mother did not testify about the payments.
2 Sec. 7491(a) does not shift the burden of proof to
respondent in this case because petitioner has not presented
credible evidence concerning the support of his sons and has
failed to provide substantiation of his claims of payments for
their support and benefit. Sec. 7491(a)(1).
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