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and (2) maintains as a home a household that constitutes "for
more than one-half of such taxable year" the principal place of
abode (as a member of such household) of a son, daughter or other
qualifying dependent (for which the taxpayer is entitled to a
deduction under section 151) of the taxpayer. Sec. 2(b).3 For
this purpose, a taxpayer is considered to maintain a household
only when: (1) The household constitutes the home of the taxpayer
for the taxpayer's taxable year, and (2) the taxpayer pays over
half of the cost of running the household. Sec. 2(b)(1); sec.
1.2-2(d), Income Tax Regs. Section 1.2-2(d), Income Tax Regs.,
further provides:
The cost of maintaining a household shall be the
expenses incurred for the mutual benefit of the
occupants thereof by reason of its operation as the
principal place of abode of such occupants for such
taxable year. The cost of maintaining a household
shall not include expenses otherwise incurred. The
expenses of maintaining a household include property
taxes, mortgage interest, rent, utility charges, upkeep
and repairs, property insurance and food consumed on
the premises. Such expenses do not include the cost of
clothing, education, medical treatment, vacations, life
insurance, and transportation. * * * [Emphasis added.]
Respondent contends that petitioner did not, during any of
the years at issue, maintain such a household, nor did she
3 Under sec. 2(b)(1)(A), with respect to a son, stepson,
daughter, stepdaughter, or descendants of a son or daughter, such
individuals need not be dependents of the taxpayer under sec. 151
unless such individuals are married, in which event, they must
also qualify as dependents under sec. 151.
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