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The divorce decree in the proceeding between petitioner and his
former spouse did not award custody to petitioner and was silent
as to whether he was entitled to the exemption otherwise
allowable under section 151. There is no evidence that
petitioner's former wife released her claim to exemptions for the
children, and there is no evidence as to the amounts for support
of the children provided by petitioner's former wife. Thus,
petitioner has failed to prove that he furnished more than
one-half the support for any of the children. Because petitioner
has not shown that he qualifies under section 152(a) or (e),
supra, he is not entitled to claim the children as dependents
during the years in issue.
Petitioner failed to prove that he maintained as his home a
household that constituted the principal abode of any of his
children for more than one-half of 1993. Thus, he does not
qualify as a head of a household under section 2(b)(1)(A)(i).
Respondent, therefore, correctly used rates applicable to single
taxpayers in computing petitioner's tax liability for that year.
Section 6662(a) imposes a 20-percent addition to tax on any
portion of an underpayment that is attributable to negligence or
disregard of rules and regulations. Sec. 6662(b)(2). Section
6662(c) defines negligence as including any failure to make a
reasonable attempt to comply with the provisions of the Internal
Revenue Code. Section 6664(c)(1) provides:
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