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his trial. Petitioner did not avail himself of these
opportunities.
Because petitioner has failed to carry his burden of proof,
we sustain respondent’s determinations concerning petitioner’s
Schedule C expenses for the years 1982 through 1987.
C. Dependency Exemptions
A taxpayer may claim exemptions for individuals who qualify
as the taxpayer’s dependents. Sec. 151(a), (e)(1).13 Section
152(a)(1) permits a taxpayer to claim his children as dependents
if the taxpayer provided over half of their support during the
calendar year.
When petitioner’s wife filed as married filing separately in
1982 and 1986, she claimed their two children as dependents.
Petitioner asserts that he was entitled to the dependency
exemptions. Under such circumstances, the right to claim the
dependency exemptions belongs to the parent who provided over
half of the children’s support. Llorente v. Commissioner, 74
T.C. 260, 269 (1980), affd. in part and revd. in part on other
grounds 649 F.2d 152 (2d Cir. 1981).
Petitioner failed to provide any evidence with respect to
this issue other than his own testimony. We are not required to
accept petitioner’s self-serving testimony in the absence of
13For taxable years beginning after Dec. 31, 1986, sec.
151(e)(1) was redesignated sec. 151(c)(1) by the Tax Reform Act
of 1986 (TRA), Pub. L. 99-514, sec. 103(b), 100 Stat. 2103.
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