Marcus V. and Polly A. Booker - Page 6

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          discussed, the burden has not shifted to respondent in this                 
               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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