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parent within the meaning of section 152(e)(1), and she is the
one who is deemed to have provided more than half of Kimberly’s
and Michelle’s support. Petitioner is not, therefore, entitled
to dependency exemptions for his daughters in 1997. Respondent’s
determination is sustained.
B. Filing Status
As relevant herein, an individual qualifies as a head of a
household if such individual (1) is not married at the close of
his taxable year and (2) maintains as his home a household that
constitutes for more than one-half of such taxable year the
principal place of abode, as members of such household, of his
daughters.6 See sec. 2(b)(1)(A). The term “principal place of
abode” is synonymous with “home”. Sec. 1.2-2(c)(1), Income Tax
Regs.
The record demonstrates that Kimberly and Michelle lived
with Ms. Phillips, their mother, from January 1 through September
4, 1997, and that they lived with petitioner, their father, from
September 5 through December 31, 1997. It is clear, therefore,
that petitioner did not maintain a home in 1997 that was his
daughters’ principal place of abode for more than one-half of the
taxable year.
6 If a taxpayer’s daughter is not married, it is not
necessary that the taxpayer be entitled to a dependency exemption
for her under sec. 151 in order to qualify for head-of-household
filing status. See sec. 2(b)(1)(A).
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Last modified: May 25, 2011