Maria Rosa Bland - Page 7

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          more than half of that amount.  Archer v. Commissioner, 73 T.C.             
          963, 967 (1980); see Cotton v. Commissioner, T.C. Memo. 2000-333;           
          Gulvin v. Commissioner, T.C. Memo. 1980-111, affd. 644 F.2d 2               
          (5th Cir. 1981); Toponce v. Commissioner, T.C. Memo. 1968-101.  A           
          taxpayer who cannot establish the total amount of support costs             
          for the claimed individual generally may not claim that                     
          individual as a dependent.  Blanco v. Commissioner, 56 T.C. 512,            
          514-515 (1971); Cotton v. Commissioner, supra.                              
               As previously stated, on her 2002 Federal income tax return            
          petitioner claimed a dependency exemption deduction for JM.                 
               During taxable year 2002, petitioner resided with Mr.                  
          Martinez and JM.  Petitioner testified that she helped Mr.                  
          Martinez support JM by paying for some clothing and food for JM.            
          Mr. Martinez corroborated petitioner’s testimony on this point.             
          Mr. Martinez further testified that he and petitioner split all             
          expenses which were incurred as a result of their cohabitation.             
          Additionally, Mr. Martinez testified that he solely supported his           
          other two children.                                                         
               We are convinced that, during 2002, petitioner helped                  
          support JM.  Unfortunately, petitioner failed to provide the                
          Court with any specific testimony or documentary evidence as to             
          any specific amounts paid in support of JM during taxable year              
          2002.                                                                       







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