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25, 2004; and (2) November 12, 2004, in the amount of $419.76,
which was deposited on December 3, 2004.3
We are convinced that, during 2004, petitioner paid expenses
on behalf of BMB and was a caring uncle to his niece. However,
petitioner has failed to provide the Court with any significant
corroborative evidence establishing the total amount of support
or that he provided over half of BMB’s support during the 2004
tax year.
Upon the basis of the record before us, respondent’s
determination on this issue is sustained.
B. Earned Income Credit
As previously stated, petitioner claimed an earned income
credit for taxable year 2004 with BMB as the qualifying child.
In the notice of deficiency, respondent disallowed the earned
income credit.
Subject to certain limitations, an eligible individual is
allowed a credit which is calculated as a percentage of the
individual’s earned income. Sec. 32(a)(1). Earned income
includes wages. Sec. 32(c)(2)(A). Section 32(c)(1)(A)(i), in
3 A difficulty is that for about half of the ABM paychecks,
the reported amounts are for “gross” with the “net” amounts cut
off in the joint exhibits. Even taking into account net income
calculations, the amounts still do not correspond with the
amounts deposited. For some of the ABM paychecks that clearly
report net income, there are no corresponding bank deposit
statements. For example, there are no statements for June, July,
September, and December 2004.
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