Emmanuel M. and Blessing N. Nwankwo - Page 11

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          Commissioner, 56 T.C. 512, 514-515 (1971); Stafford v.                      
          Commissioner, supra at 518.                                                 
               With respect to the elder Mrs. Nwankwo, petitioners provided           
          credible evidence that Caroline Nwankwo remained in their home              
          throughout all of 2002, that she did not work outside their home,           
          and that they provided all of her support by way of food,                   
          clothing, shelter, and medical care.  We are satisfied,                     
          therefore, that petitioners provided more than half of the elder            
          Mrs. Nwankwo’s support in taxable year 2002.                                
               With respect to Raphael Nwankwo, petitioners provided                  
          credible evidence that although the elder Mr. Nwankwo left their            
          home in late January 2002, they contributed more than half of his           
          total financial support for the taxable year.  Petitioners                  
          offered credible testimony that between January and August 2002,            
          they provided Mr. Nwankwo with $1,450 in support for food,                  
          clothing, and medical care.  In addition, petitioners also paid             
          approximately $700 for travel-related expenses.  When he returned           
          to Nigeria in late January 2002, the elder Mr. Nwankwo received a           
          state pension of $60 a month.  This was his only source of income           
          in Nigeria.  During this time, petitioners remained the primary             
          source of Raphael Nwankwo’s economic support, often sending cash            
          to him in Nigeria.  He died in August 2002.                                 
               However, while we are satisfied that petitioners provided              
          more than half the support for both Raphael and Caroline Nwankwo            






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