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On brief, petitioner attempts to shift the blame for lack of
substantiation to respondent by arguing that “Respondent merely
had to substantiate this item for the record while the Tax
Preparer [her former husband and Melissa’s father, Ronald
O’Donnell] was sitting on the witness stand under Cross
Examination by Respondent.” But the burden is on petitioner, not
respondent, to substantiate petitioner’s deductions. See sec.
7491(a)(2)(A); Rule 142(a). Petitioner has not shown that she is
entitled to a $617 deduction for tax preparation fees.
III. Dependency Exemption for Melissa
Here, again, because petitioner has failed to introduce
credible evidence that she is entitled to a dependency exemption
for Melissa, she retains the burden of proof with respect to that
issue. See sec. 7491(a)(1); Rule 142(a).
Section 151 allows deductions for personal exemptions.
Besides providing exemptions for the taxpayer and, in certain
circumstances, the taxpayer’s spouse, section 151 provides
exemptions for dependents of the taxpayer. See sec. 151(c).
Section 152(a) defines the term “dependent”, in pertinent part,
to include a son or daughter of the taxpayer “over half of whose
support, for the calendar year * * * was received from the
taxpayer”. “Support” includes “food, shelter, clothing, medical
and dental care, education, and the like.” Sec. 1.152-
1(a)(2)(i), Income Tax Regs. Assuming petitioner satisfies the
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