1

 The Honorable Ralph R. Erickson, United States District Judge for the

District of North Dakota, sitting by designation.

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United States Court of Appeals

FOR THE EIGHTH CIRCUIT

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No. 03-3180

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Geneve Hartfield, *

*

Plaintiff - Appellant, *

* Appeal from the United States 

v. * District Court for the Western 

* District of Missouri.

Jo Anne B. Barnhart, Commissioner of *

Social Security, *

*

Defendant - Appellee. *

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Submitted: March 12, 2004

 Filed: September 27, 2004 

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Before RILEY and MELLOY, Circuit Judges, and ERICKSON,1

 District Judge.

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MELLOY, Circuit Judge.
2

 The Honorable Ortrie D. Smith, United States District Judge for the

Western District of Missouri.

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Geneve Hartfield appeals the district court’s2

 order affirming the Commissioner

of Social Security’s (the “Commissioner”) decision to deny her application for

parent’s insurance benefits. We affirm.

I.

Hartfield applied for parent’s insurance benefits under the Title II of the Social

Security Act (the “Act”), 42 U.S.C. §§ 401 et seq. (2004), on August 16, 1999. She

alleged that her son, David Cannon, provided one-half of her financial support in the

relevant period of time before his death on December 19, 1994, and as a result, she

was entitled to parent’s insurance benefits under the Act. The application was denied

by the Social Security Administration, reconsidered and still denied, and then brought

before an Administrative Law Judge (“ALJ”). The ALJ found that because Hartfield

did not establish that she received at least one-half of her support from Cannon, she

was not entitled to parent’s insurance benefits. The Appeals Council of the Social

Security Administration denied Hartfield’s request for review of the decision by the

ALJ. Subsequently, the district court affirmed the decision of the Commissioner.

Hartfield now appeals the district court’s ruling. 

Hartfield alleges that she received over one-half of her support from her son

during the relevant time period for her estimated expenses of $1400 per month.

During the same period, she received a Social Security retirement benefit of $461.00

per month and food stamps worth $23.00 per month. Hartfield estimated that her son

paid for the remainder of her expenses. Hartfield further alleged that she often

received cash (including regular $200 monthly payments) from Cannon, but

acknowledged that this money was used to pay her grandchildren’s expenses in

addition to her own. These cash transactions were not recorded with receipts. During
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this time period, Cannon and his two children lived with Hartfield. She provided

room, board, childcare for both children, and use of the her vehicle to Cannon. 

II.

We review de novo the district court’s decision to uphold the denial of Social

Security benefits, Pettit v. Apfel, 218 F.3d 901, 902 (8th Cir. 2000). However, our

review of the Commissioner’s final decision is deferential and we review that

decision only to ensure that it is supported by substantial evidence in the record as a

whole. Dixon v. Barnhart, 353 F.3d 602, 604 (8th Cir. 2003). Substantial evidence

is evidence that a reasonable mind would find adequate to support a decision,

considering both evidence that detracts from and evidence that supports the

Commissioner’s decision. Young v. Apfel, 221 F.3d 1065, 1068 (8th Cir. 2000).

However, the mere fact that some evidence may support the opposite conclusion than

that reached by the Commissioner does not compel this Court to reverse the decision

of the ALJ. Gaddis v. Chater, 76 F.3d 893, 895 (8th Cir. 1996). Further, “‘[i]f, after

review, we find it possible to draw two inconsistent positions from the evidence and

one of those positions represents the Commissioner’s findings, we must affirm the

decision of the Commissioner.’” Dixon, 353 F.3d at 605 (quoting Nguyen v. Chater,

75 F.3d 429, 431 (8th Cir. 1996). 

The primary issue in this case is whether Hartfield has met her statutory burden

to prove that she was receiving at least one-half of her support from Cannon for the

twelve-month period preceding his death. 42 U.S.C. § 402(h)(1)(B) (2004); 20

C.F.R. § 404.366(b) (1999). The Commissioner issued a set of internal rules, the

Program Operations Manual System (“POMS”) to aid in determinations such as these.

While these internal rules do not have legal force and do not bind the Commissioner,

courts should consider them in their findings. Shontos v. Barnhart, 328 F.3d 418, 424

(8th Cir. 2003). The relevant section from the POMS requires that the Commissioner

calculate a deceased wage earner’s “net contribution to the support of the parent and
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compare that amount with the parent’s income from other sources.” RS

01301.195.B.2. Further, the rule requires that the value of room, board, and other

benefits provided by the parent to the child be considered.

Hartfield’s income (from social security and food stamps) during the relevant

time period was approximately $484. At first glance, simple subtraction implies that

Hartfield was receiving payment for over one-half of her expenses from another

source ($1400 minus $484 equals $916). However, the figures offered by Hartfield

do not account for the value of the room and board received by Cannon for himself

and his children. Hartfield also allowed Cannon to use her primary vehicle. The

district court and the ALJ estimated that the combined value of child care provided

by Hartfield was quite substantial.

It is inadequate for Hartfield to simply subtract her income from her estimated

total expenses when her son and two children shared in those expenses. Instead,

Hartfield must prove that Cannon paid over one-half of her expenses and not over

one-half of the total household expenses. Hartfield only offered tax returns, copies

of bills, and copies of checks she wrote from her own account — none of which

demonstrate the amount of money she received from her son to pay for her expenses.

There were no deposit slips or other evidence to document any money she received

from her son for her own care or that of her son and grandchildren. As a result, the

finding that Hartfield did not receive more than one-half of her total expenses from

Cannon is supported by substantial evidence in the record as a whole.

We affirm the judgment of the district court.