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discussed, the burden has not shifted to respondent in this
case.4
With respect to the first issue, petitioners claimed section
151 dependency exemption deductions for years 1999 and 2000 for
Mrs. Booker’s mother, Carrie Mayfield (Ms. Mayfield). Ms.
Mayfield did not reside with petitioners but lived alone in
Greenville, South Carolina. During 1999, Ms. Mayfield suffered a
number of strokes and spent a portion of the year in the
hospital. Petitioners contend they sent Ms. Mayfield money
almost every month to help pay her rent and insurance but
acknowledged they were not her sole source of support. Ms.
Mayfield had other children and grandchildren who often
contributed to Ms. Mayfield’s support. Ms. Mayfield also
received Social Security benefits of approximately $700 a month
and, additionally, received Medicare assistance. Petitioners
also acknowledged that Ms. Mayfield received her deceased
husband’s pension every month. The amount of that pension was
not disclosed. Petitioners, however, were unable to establish
the specific amounts they contributed to Ms. Mayfield for the
years in question. Mrs. Booker testified: “I would give her
money certain times of the year. Not exactly month per month,
like this month I might send her $500, or maybe two months from
then, I will send her another $500”. Mrs. Booker also testified
4See supra note 2.
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