Juanita Carter - Page 15

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          provide over one half of the cost of maintaining such a                     
          household.                                                                  
               During the years in question, petitioner lived in her home             
          with Char Nea and Shauneille.  The Court has held that petitioner           
          failed to prove she contributed more than one half of Char Nea's            
          support for any of the years at issue; thus, she is not entitled            
          to a dependency exemption for Char Nea for any of those years.              
          Moreover, petitioner conceded that she is not entitled to                   
          dependency exemptions for Shauneille for 1990 and 1991, and she             
          did not claim them for 1989 and 1992.  Consequently, neither Char           
          Nea nor Shauneille can be considered as qualifying dependents for           
          purposes of section 2(b).  Likewise, petitioner failed to prove             
          she provided over one half of the cost of maintaining a household           
          for any other qualifying dependent.                                         
               On this record, the Court holds that petitioner is not                 
          entitled to head-of-household filing status for any of the years            
          at issue.  Respondent is, therefore, sustained on this issue.               
               The fourth issue is whether petitioner is entitled to a                
          casualty loss deduction, under section 165(a), in the amount of             
          $5,039 for 1989.  On her income tax return for 1989, petitioner             
          included five Forms 4684, Casualties and Thefts, pursuant to                
          which she claimed casualty losses of $6,488.  After application             
          of the 10-percent adjusted gross income floor, the amount of the            
          loss, $4,389, was carried over to Schedule A, Itemized                      





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