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Respondent disallowed all of the claimed dependents on the ground
that petitioner failed to establish that she had provided more
than one-half of their support.
At trial, petitioner conceded her claim to a dependency
exemption for her sister, Shauneille, for the years 1990 and
1991.
Geneva Carter, John Carter, Albert Carter, and Pierce Carter
lived in a house, separate from petitioner but which was owned by
petitioner and, for convenience, is referred to as the Lurch
Street house. This house was fully paid for; however, on March
19, 1990, the house was acquired by condemnation by the St. Louis
airport authority and, therefore, was no longer owned by
petitioner. Petitioner's relatives, however, continued living in
the house until July 3, 1991, when they moved to another house
petitioner acquired as a replacement for the Lurch Street house
that was condemned. Neither petitioner nor her relatives paid
any rent to the St. Louis airport authority during the period
from March 19, 1990, to July 3, 1991.
Char Nea Harris, petitioner's grandniece, and Shauneille,
petitioner's sister, lived with petitioner at their house, which,
for convenience, is referred to as the Amblewood Street
residence. That home was encumbered with a mortgage, as to which
petitioner was allowed itemized deductions for home mortgage
interest and real estate taxes.
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