Shaun Dion Brandon - Page 8

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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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