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sufficient evidence to establish his claim that his wife was
incompetent in 1990 and 1991, he would not meet the requirements
of section 7703 for persons who are married to file as head of
household. One of the requirements of the statute is that a
married taxpayer support either a son, stepson, daughter, or
stepdaughter to file as head of household. Petitioner makes no
claim that he supported a son or daughter, but claims that he was
head of household because his mother was a member of his
household. Since petitioner testified that he was married in
1990, 1991, and 1992, we hold that petitioner's correct filing
status in each of these years is "married filing separate". It
follows that in computing petitioner's income tax, the threshold
amount of married filing separate should be used to determine the
amount of any exemption to which petitioner is entitled.
Petitioner argues that in any event he is entitled to a
dependency exemption for his mother in 1990 and 1991.
Under section 151, a taxpayer is allowed an exemption for
himself and an exemption for each dependent as defined in section
152: (1) Whose gross income for the calendar year in which the
taxable year of the taxpayer begins is less than the exemption
amount; or (2) who is a child of the taxpayer and who has not
attained the age of 19 at the close of the calendar year in which
the taxable year of the taxpayer begins, or is a student. Sec.
152(b) and (c). Under section 152(a)(4), a "dependent" includes
the father or mother of the taxpayer, if the father or mother
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