Charles R. Roberts - Page 5

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          the principal place of abode of the father or mother of the                 
          taxpayer, if the taxpayer is entitled to a deduction for such               
          parent under section 151.  Sec. 2(b)(1)(B).  We hold that                   
          petitioner may not claim head of household status because,                  
          as we have held above, he is not entitled to a deduction for Mr.            
          Roberts under section 151 and thus does not meet the definition             
          of head of household.                                                       
               The final issue for decision is whether petitioner is                  
          entitled to a deduction for his father's medical expenses.                  
          Section 213(a) allows as a deduction the expenses paid during the           
          taxable year for medical care of the taxpayer's dependent as                
          defined in section 152.  Again, since we have already held that             
          Mr. Roberts is not petitioner's dependent under section 152, we             
          further hold that petitioner is not entitled to a deduction for             
          Mr. Roberts' medical expenses because the requirements of section           
          213(a) are not met.                                                         
               To reflect the foregoing,                                              


                                                  Decision will be entered            
                                                  for respondent.                     












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