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Although we find petitioner’s testimony credible as to the
fact that he provided support for his nephew in the aftermath of
a fire which destroyed the child’s maternal home, the record
based solely on the testimony proffered is vague and incomplete.
Petitioner has not kept records of how much he spent on SAB, nor
could he reconstruct for the Court a dollar amount of total
support provided for his nephew. Petitioner also testified at
trial that other family members, including his mother and
grandmother, provided financial support for SAB, although he
could not offer an accounting for these funds. While we find
that petitioner made valiant efforts to sustain and support his
nephew in the aftermath of a family tragedy, petitioner
nonetheless failed to meet the statutorily imposed requirement to
establish the amount of his contributions to the support of SAB
during the taxable year 2003. Because petitioner failed to
establish the total amount of support from all sources, we are
unable to conclude that petitioner provided more than one-half of
the total support for SAB, and therefore we sustain respondent on
this issue.
B. Head-of-Household
As previously stated, petitioner filed his 2003 Federal
income tax return as a head of household, and respondent changed
the filing status to single in the notice of deficiency.
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