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is petitioner's daughter and was 34 years old in 1994. Nicole
and Latoya are Melanie's daughters and petitioner's
granddaughters. In 1994, Latoya was 18 and Nicole was 13 years
of age. Petitioner conceded prior to trial that she is not
entitled to a dependency exemption for Latoya for 1993 and 1994.
Petitioner claims that she provided over one-half of the support
for Melanie and Nicole during the years in issue. Petitioner
claimed head of household status for 1993 and 1994 based upon her
contention that she provided the principal place of abode for
Melanie, Nicole, and Latoya during those years.
In 1966, petitioner married Lee Perry. She became legally
separated from Lee Perry in 1970 and divorced him in July 1994.
Petitioner married James Jones in August 1994. During the trial,
petitioner introduced into evidence numerous checks from a joint
checking account she maintained with James Jones. Many of the
checks were written prior to the time petitioner remarried. Mr.
Jones did not testify during the trial of this case.
At trial, petitioner produced 30 canceled checks from the
joint checking account payable to various clothing and department
stores.3 Petitioner claimed that the checks represented payments
for items purchased on behalf of Melanie and Nicole during 1993
3
Most of petitioner's checks were payable to the following
stores: Strawbridge and Clothier, J.C. Penney, Lane Bryant,
Dress Barn, Clover, Macys, and Wanamakers, and many of the checks
were for payments on store charge cards.
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