Matthew D. Gilmore - Page 5

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          with the requirements of section 7491(a)(2)(A) and (B) to                   
          substantiate items, maintain required records, and fully                    
          cooperate with respondent’s reasonable requests.  Accordingly,              
          the burden does not shift.                                                  
               1.  Dependency Exemption Deductions                                    
               A taxpayer may be entitled to claim as a deduction an                  
          exemption amount for each of his or her dependents, over half of            
          whose support is provided by the taxpayer.  Secs. 151(c)(1),                
          152(a).  A dependent includes a son or daughter of a sister of              
          the taxpayer.  Sec. 152(a)(6).                                              
               As to the support test, a taxpayer generally must provide              
          more than half of a claimed dependent’s support for the calendar            
          year in which the taxable year of the taxpayer begins.  Sec.                
          152(a).  In order to satisfy this test, a taxpayer must establish           
          the total support expended on behalf of the claimed dependents              
          from all sources for the year and demonstrate that he provided              
          more than half of this amount.  See Archer v. Commissioner, 73              
          T.C. 963, 967 (1980); Blanco v. Commissioner, 56 T.C. 512, 514-             
          515 (1971).                                                                 
               There is an absence of evidence relating to the total amount           
          of support as well as petitioner’s share of support.  While there           
          is some general information as to purchase of groceries, payment            
          of rent, and payments of other household expenses by petitioner,            
          we cannot conclude from this meager record the amount of the                

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