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contributions toward her support. He explained that
documentation pertaining to his mother had been put in storage
when she died and that “It’s just too much stuff to go through.”
We are unable reasonably to infer the required information from
the evidence presented. Without other competent evidence, we
cannot determine that petitioner provided more than half of Mrs.
Morgan’s overall support. Petitioner is asking us to make a
guess that he provided more than half his mother’s support during
1997 on the basis of his unsupported self-serving testimony and
very little more. We cannot make a decision based on such a
guess. Accordingly, we hold that petitioner is not entitled to a
dependency exemption deduction for Mrs. Morgan, and respondent’s
determination in this regard is sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011