- 8 -
T.C. 512, 514 (1971). Petitioner has not provided evidence of
the total amount of support provided for Stacy Brown for either
year at issue, except for his own testimony. He testified that
he provided all her room and board and other support. The Court
is not required to accept petitioner’s self-serving testimony,
particularly in the absence of corroborating evidence. See
Geiger v. Commissioner, 440 F.2d 688, 689 (9th Cir. 1971), affg.
per curiam T.C. Memo. 1969-159; Urban Redev. Corp. v.
Commissioner, 294 F.2d 328, 332 (4th Cir. 1961), affg. 34 T.C.
845 (1960).
It is not necessary under section 152(a)(9) that an
individual be related to the taxpayer to qualify as his
dependent. However, in order for an unrelated individual to
qualify as a dependent under section 152(a)(9), such individual
must live with the taxpayer and be a member of the taxpayer’s
household throughout the entire taxable year of the taxpayer.
Trowbridge v. Commissioner, 268 F.2d 208, 209 (9th Cir. 1959),
affg. per curiam 30 T.C. 879 (1958); McMillan v. Commissioner, 31
T.C. 1143, 1145-1146 (1959); sec. 1.152-1(b), Income Tax Regs.
Petitioner offered no evidence that Stacy Brown was a member
of his household for the entire year of 1994 or 1995 except for
his own testimony.
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