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roborated by reliable evidence. We found the testimony of
petitioner’s mother to be in material respects not based upon her
personal knowledge, conclusory, and serving the interests of her
son petitioner. We found the testimony of Ms. Srase to be in
material respects not based upon her personal knowledge,
conclusory, and serving the interests of her longtime friend
petitioner. We are not required to, and we shall not, rely on
the testimonies of petitioner, his mother, and Ms. Srase in order
to establish petitioner’s position with respect to the issues
presented in this case. See, e.g., Tokarski v. Commissioner, 87
T.C. 74, 77 (1986).
Claimed Dependency Exemption Deduction
Section 151(a) permits a taxpayer to deduct an exemption
amount for each dependent as defined in section 152. As perti-
nent here, section 152(a) defines the term “dependent” to include
an individual who receives from the taxpayer over half of such
individual’s support for the calendar year in which the taxable
year of the taxpayer begins and who is the taxpayer’s daughter.
Sec. 152(a)(1). As also pertinent here, if the taxpayer’s
daughter receives over half of her support during the calendar
year from her parents who live apart at all times during the last
six months of such year and if such daughter is in the custody of
one or both of her parents for more than one-half of such year,
the daughter will be treated for purposes of section 152(a) as
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